Environmental, Social and Governance (ESG) Policy

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Environmental, Social and Governance (ESG) Policy
Environmental, Social and
Governance (ESG) Policy
Environmental, Social and Governance (ESG) Policy

Environmental, Social and Governance (ESG) Policy

The purpose of this Policy is to set out the
environmental, social and governance (ESG)
principles that we take into account in the course
of operating our company, evaluating investments
and managing assets for the funds that we sponsor.

We believe that good governance practices and responsible
corporate behavior contribute to the long-term success of
companies, and are critical to well-functioning markets. We also
believe that strong corporate governance helps reduce investment
risk and ensures that investor capital is used effectively.
Starwood Capital Group is proud to be both carbon neutral
and a signatory of the United Nations-supported Principles for
Responsible Investment.

The following reflects the principles that guide us and the goals
that we strive to achieve.
Environmental, Social and Governance (ESG) Policy

                  As a core philosophy, Starwood Capital Group is committed to responsible
                  investing through environmental sustainability, as well as responsible
                  community development.
                  The commitment to environmentally responsible investments starts with our acquisition team.
                  Starwood Capital Group conducts rigorous reviews before acquiring properties to ensure clean
                  environmental backgrounds. Starwood Capital Group’s Investment Committee reviews the due
                  diligence performed by our in-house acquisitions team, and our legal team works with transaction
                  counsel, local counsel and third parties (environmental consultants, architects, etc.) to identify any
                  potential environmental issues and request additional due diligence when necessary.

                  At Starwood Capital Group, we do not just look at real estate as it is today—we see it as it could
                  be. This philosophy extends to our approach to environmentally responsible investing. Instead of
                  accepting the status quo that says conservation is a secondary concern when managing property,
                  we are committed to setting a new standard for the private equity industry.


                  Starwood Capital Group’s eco-conscious approach to investing includes office and residential properties
                  around the world. Since our inception in 1991, a number of assets owned by the Firm and its affiliates have
                  garnered recognition for their environmentally friendly design and operations, including but not limited to:

                  Manhattan’s first Platinum            LEED Gold                              WARSAW, POLAND
                  LEED-certified condominium project                                           Poland’s first building to earn
                                                        THE COLONNADE, MINNEAPOLIS, MN         BREEAM Excellent
                  400 CAPITOL MALL,                     LEED Gold
                  SACRAMENTO, CA                                                               ST VINCENT PLAZA,
                  LEED Platinum                         PCT OFFICE CAMPUS, LOS ANGELES, CA     GLASGOW, SCOTLAND
                                                        LEED Gold                              BREEAM Excellent
                  SEAMARK BUILDING (ELM PARK)
                  DUBLIN, IRELAND                       WELLS FARGO CENTER,                    SOUTH BANK CENTRAL,
                  LEED Platinum                         MINNEAPOLIS, MN                        LONDON, ENGLAND
                                                        LEED Gold                              BREEAM Excellent
                  ENERGY PARK, MILAN, ITALY
                  LEED Platinum                         ROUTE 128 OFFICE CAMPUS,               ST LEONARDS, SYDNEY, AUSTRALIA
                                                        BOSTON, MA                             NABERS 5
                  MILLENIA LAKES, ORLANDO, FL           LEED Gold
                  LEED Gold                                                                    ZENITH, SYDNEY, AUSTRALIA
                                                        JEFFERSON MARKETPLACE,                 NABERS 5
                                                        WASHINGTON, D.C.
                                                        LEED Silver
Environmental, Social and Governance (ESG) Policy

                                                                           ENERGY PARK, MILAN, ITALY


       Our goal is to obtain Energy Star Certification (score of 75 or greater) for all U.S. office
       buildings, if we can do so cost effectively. We also plan to conduct high-level energy
       audits for the entire U.S. office portfolio. For our European portfolio, our goal is to obtain
       LEED or BREEAM certifications for our office refurbishments and redevelopments, if we
       can do so cost effectively. We also plan to conduct high-level energy audits on targeted
       parts of our European office portfolio.

                                       PCT OFFICE CAMPUS LOS ANGELES, CA

                                       DUBLIN, IRELAND
Environmental, Social and Governance (ESG) Policy


                   Nowhere is the Firm’s commitment more apparent than 1 Hotels. Operated
                   by Starwood Capital Group affiliate SH Hotels & Resorts, this luxury lifestyle
                   brand represents hospitality with a purpose: To capture the beauty of nature
                   while being a platform for change for the luxury traveler. As a mission-driven
                   luxury lifestyle hotel brand inspired by nature, 1 Hotels cultivates the best
                   of sustainable design and architecture, together with extraordinary comfort
                   and an unrivaled level of service. We are inspired by a simple idea that those
                   who travel the world also care about it.

                   1 Hotels upholds this vision by channeling nature through design and culinary partnerships, while
                   connecting with the local community and taking sustainable steps to make a difference.

                   All 1 Hotels are designed to meet the stringent requirements of LEEDv4 Silver-level certification
                   (or local equivalent), the rating system administered by the U.S. Green Building Council that is
                   the industry standard to evaluate building performance. The daily operation of each 1 Hotel is
                   carefully planned to minimize the property’s carbon footprint by minimizing energy use, leveraging
                   local resources, conserving non-renewable materials, minimizing plastic/paper consumption and
                   reducing landfill waste.

Environmental, Social and Governance (ESG) Policy

Sustainability keystones are the foundation on which we base all our
design, construction and operational decisions. From there, we bolster
our brand through the application of Evergreen Standards, including:

• Sick Building Assessment                WASTE MANAGEMENT
• Solar Generation and Water             • L ocally Sourced Building Materials and
  Reclamation Feasibility Study             Furniture (20%, 500 Miles)
• Local Community and Ecology Report     • Organic Waste Digester
• Biophilic Design Assessment            • In-Room and BOH Waste Sorting
                                            (Landfill, Recycling, Organic Waste)
BUILDING PLANNING                         CLEAN WATER
•   aylighting Design
   D                                      • B ase-Building Water Filtration System
•  Light Pollution Reduction             • On-Floor distribution
•   Cool Roof                            • Water Bottle Filling Stations in Public   IN-ROOM WATER FILTRATION SYSTEM

•    On-Site Garden or Farm                Areas                                      1 HOTEL BROOKLYN BRIDGE, BROOKLYN, NY

•     Access to Electric Car Charging
                                          CLEAN, FRESH AIR
  Stations                                                                             In operations, we aim to reduce
                                          • M inimum Indoor Air Quality
• Green-E Certified Fleet                  Performance                                single-use items throughout the
                                          • Construction Air Quality Management       properties, from reducing dependency
• E fficient Irrigation System and
                                            Plan                                       on paper to not utilizing single-use
  Indigenous Landscaping                  • Low-Emitting Materials                    plastic. This includes a paperless
• Efficient/Low-Flow Plumbing Fixtures   • Indoor Air Quality (IAQ) Monitoring       approach to the guest experience that
• Cooling Tower Management               • Carbon Dioxide Monitoring                 includes electronic check-in, bedside
• Building Level Water Metering          • Minimum Efficiency Reporting Value        chalkboards instead of notepads, and
                                            (MERV) Filtration Media
                                                                                       the 1 Hotels app that provides personal
ENERGY MANAGEMENT                         • Operable Guestroom Windows
                                          • Minimum Acoustical Performance
                                                                                       devices with pre-loaded newspapers
• G uestroom Energy Management
  Controls                                                                             and magazines.
• Automated Public Area Controls with    PERFORMANCE IMPROVEMENT
  Building                                • E nvironmental Monitoring Platform        1 Hotels’ philosophy regarding its
                                          • Annual Sustainability Capital             culinary offerings is: “Ingredients
MANAGEMENT SYSTEMS (BMS)                    Expenditure Plan
                                                                                       first.” The company has partnered with
INTEGRATION                               • Annual Property Assessment
• B uilding Management System                                                         celebrated chefs united by a common
                                          • Ongoing Commissioning Plan
• Fundamental Systems Commissioning      • Preventative Maintenance Plan             focus on ingredients, seasonality
  and Verification                                                                     and responsible sourcing from local
• Enhanced Energy Performance                                                         purveyors. In addition, farm stands
  Modeling                                                                             located in the lobby of each hotel
• Building Level Energy Metering                                                      offer snacks from local farmers and
• Maximum Lighting Levels
• Variable Speed Drives on Mechanical
Environmental, Social and Governance (ESG) Policy

                         1 HOTEL SOUTH BEACH, MIAMI BEACH, FL

                         1 Hotels launched in March 2015 with the opening of 1 Hotel & Homes South Beach in
                         Miami, Florida, on the site of the former Gansevoort Miami South Beach. Situated on
                         600 feet of pristine beachfront property, the resort benefited from a comprehensive
                         refurbishment ensuring that nature is omnipresent—from the graceful twist of driftwood
                         furnishings to the soothing sounds of the ocean and abundance of living materials.

                        A NEW 1 HOTEL IS COMING TO KAUAI’S NORTH SHORE

                                                                   erforming a deep energy retrofit and redesigning
                                                                • P
                                                                  the central plant, while reducing the embodied
                                                                  carbon of the project through re-use of an existing
                                                                • R
                                                                   ainwater capture and greywater re-use, with a
                                                                  water feature cascading down the property site
                                                                • Restoring turf grass to natural landscaping
                                                                   eestablishing a native Hawaiian fish pond through
                                                                • R
                                                                  coordination with the local community
                                                                • O
                                                                   pen-air lobby and common-area experience,
                                                                  decreasing need for mechanical ventilation
                                                                • D
                                                                   estination spa experience with associated wellness
1 HOTEL HANALEI BAY, KAUAI, HI                                    rooms
Environmental, Social and Governance (ESG) Policy

                                      ENVIRONMENTAL AWARENESS EXTENDS TO
                                      HOSPITALITY PROPERTIES GLOBALLY

                                      Starwood Capital’s commitment to sustainable hotel
TREEHOUSE LONDON, LONDON, ENGLAND     operations has not been confined to 1 Hotels. In June
                                      2019, Starwood Capital Group announced a new hotel
                                      brand, Treehouse Hotels, which will also embrace
                                      sustainability practices throughout its portfolio.

                                      At the Sea Island Resort in Georgia, an ambitious sea turtle nesting
                                      program—overseen by a full-time naturalist on staff—focused on both
                                      conservation and education. During our ownership, approximately
                                      5,000 of the endangered creatures are hatched on the resort’s beach
                                      each year, with hotel guests invited to observe both adult and baby
                                      turtles as they embark upon their critical journeys to and from

                                      Newly constructed and opened in May 2014, The Hilton Garden Inn
                                      Washington, D.C./Georgetown Area is a premium select-service hotel
                                      that received LEED Silver certification due to its many green features—
                                      including condensate and ventilation recovery systems, low volatile
                                      organic compound finishes and seven separate vegetative roofs over
                                      three different levels of the property.

                                      We embrace environmental policies in our entire full and select-service
                                      hotel portfolios by often:
                                      • Conserving water by encouraging guests to hang towels to signal
                                           re-using vs. washing/replacing
SEA ISLAND RESORT, SEA ISLAND, GA     • Awarding bonus points if guests waive housekeeping services
                                      • Limiting cleaning schedule for extended stay guests
                                      • Providing recycling bins in guestrooms
                                      • Replacing parking lights with LED

                                      At these and our other hotel properties, Starwood Capital continues to
                                      show that taking care of guests and taking care of the environment are
                                      not mutually exclusive.
Environmental, Social and Governance (ESG) Policy

                                                                BUCK LAKE, HARMONY, FL

                                                         TERRAMOR, TEMESCAL VALLEY, CA


Through our many land investments across multiple funds, Starwood Capital
Group takes a hands-on approach to preserving irreplaceable habitats and
minimizing the impact of development on fragile ecosystems. One of our
Florida developments earned Green Development certification from the Florida
Green Building Coalition based on a number of community-wide practices that
follow sustainable principles, including:
• A
   LAND-USE MIX that allows residents                 • EXTENSIVE
                                                                      USE OF NATIVE PLANTS and
  to meet most daily needs within a short                 grasses in landscaping.
  distance of their homes— making walking,
  cycling or neighborhood-type vehicles a               • T
                                                           WO NATURAL LAKES of approximately
  viable first choice for transportation.                 500 acres apiece with protected shorelines
                                                          for recreation.
       THAN 7,000 ACRES OF OPEN
  SPACE out of the community’s total area of            • D
                                                           ARK SKY-COMPLIANT LIGHTING to
  approximately 11,000 acres.                             reduce glare, eliminate wasted light and
                                                          preserve our star-filled sky.
     PRIVATE LANDS that conserve water by
     responding to landscape growing conditions.

In Colorado, we have clustered development areas to maintain corridors for wildlife such as deer, elk,
bear and wild turkey. In California, we have taken the view that thoughtful environmental design in our
land planning not only preserves wildlife habitat, but also adds value and enjoyment to our residential
owners and plays a large part in their choice to live in our communities. We design and build hiking trails
that provide residents with great outdoor exercise as well as help them commune with nature.

In addition to our active approach to land planning, we have employed a number of measures to protect
the land and natural resources. These include building bridges to avoid areas with sensitive oak trees
and other natural habitats and conserving water by (1) constructing reclaimed water storage and
distribution systems, (2) utilizing native and drought-resistant landscaping, and (3) using reclaimed
water for some irrigation.

We often designate permanent open spaces when developing land. In one case, our partnership
invested $13M to restore a permanent wildlife corridor 2.5 miles long to assist in the migration of local
wildlife. Our corridor was the final connection point between the Santa Ana Mountains and the Orange
County coastal habitat. Our efforts across our investments prove that, even as we develop land, we can
help preserve it as well.


                    As corporations and individuals place a greater emphasis on the health of the
                    environment in their decisionmaking processes, clean sources of energy have
                    seen a surge in interest. Starwood Capital Group affiliate Starwood Energy
                    Group has emerged as a leader in the industry’s push toward greener energy
                    production. Since its founding in 2005, the team has invested in a number of
                    clean energy projects across North America— including wind, solar and other
                    renewable energy facilities—including:

                   • STARWOOD
                                 SOLAR SAULT STE.                 • N
                                                                       AUTILUS SOLAR ENERGY, Summit, New
                     MARIE, Ontario, Canada: A three-phase,           Jersey: A leading solar power producer.
                     69-megawatt DC solar photovoltaic
                     project—one of the largest solar power         • SHANNON
                                                                                WIND PROJECT, Clay County,
                     plants in Canada.                                Texas: A 204-megawatt. The project
                                                                      entered into a 13-year Renewable Energy
                   • B
                      ERLIN STATION, Berlin, New Hampshire:         Credit purchase agreement with Facebook,
                     A 75-megawatt, wood-fired power plant—           Inc.
                     one of the largest biomass power plants in
                     the Northeast.                                 • STEPHENS
                                                                                RANCH WIND PROJECT, Lynn
                                                                      County, Texas: A two-phase project totaling
                   • GAINESVILLE RENEWABLE ENERGY                   376 megawatts that began commercial
                       CENTER, Gainesville, Florida:                  operations in November 2014. Phase II of
                       A 100-megawatt, wood-fired power plant—        the project was completed in May 2015.
                       one of the largest biomass power plants in
                       the U.S.                                     • H
                                                                       ORSE CREEK, Knox and Haskell Counties,
                                                                      Texas: 230-megawatt wind projects that
                   • HUDSON AND NEPTUNE                             began commercial operations in October
                       TRANSMISSION PROJECTS, New York                2016. Starwood Energy sold its interests in
                       and New Jersey: Two projects that, upon        the project to MEAG, the investment arm
                       commencing operations in 2007 and 2013,        of MunichRE, and Skyline Renewables in
                       provided customers in New York City and        separate transactions in 2017 and 2018.
                       Long Island with access to significantly
                       cheaper and more diverse sources of          • NORTH
                                                                             WEST OHIO WIND, Ohio:
                       energy, including low-cost shale gas,          A 100-megawatt wind farm. The project is
                       nuclear and renewables.                        contracted to General Motors for 100% of
                                                                      the project output under a long-term power
                                                                      purchase agreement.

Good for the Environment   Starwood Capital Group has
                           demonstrated time and again that
Good for Our Investors     environmentally conscious investing
                           can also be profitable investing.
                           Whether employed for hotels, offices,
                           residential or energy infrastructure,
                           sustainable design and practices often
                           result in more efficient processes
                           that reduce expenses and enhance
                           the value of real estate assets. Such
                           properties also benefit from the
                           growing demand from eco-mindful
                           tenants, buyers and investors.

                           As an industry leader, we embrace
                           the opportunity to serve as stewards
                           of the environment to encourage
                           sustainability. We are just as serious
                           about serving as stewards of our
                           investors’ hard-earned capital
                           to maximize returns. Across our
                           portfolio, we are have demonstrated
                           that both of these critical
                           responsibilities can go hand-in-hand.

                                       STEPHENS RANCH WIND PROJECT
                                                    LYNN COUNTY, TX

                   Starwood Capital Group is committed to enriching the communities in
                   which we live, work and serve—and in protecting the interests of all our
                   stakeholders—including investors, partners, vendors, employees, the
                   community and the environment. We are guided by the following principles:

                   Create a Positive Workplace Environment
                   Starwood Capital Group employees are dynamic, self-motivated, team-oriented individuals who
                   possess the ability to help implement innovative solutions that ultimately benefit our investors.
                   To support all our employees in their efforts, the Firm seeks to provide a comfortable and collegial
                   environment in which to work. Starwood Capital Group adheres to safe workplace guidelines such
                   as OSHA regulations, including monitoring indoor air quality and providing a clean environment for
                   employees. We are also concerned for the safety of our employees when commuting to and from
                   the office. For example, we send out weather alerts before and during storms, and employees are
                   encouraged to work from home if weather conditions are potentially hazardous.

                   Starwood Capital Group also hosts American Red Cross CPR and Defibrillator Certification onsite
                   training sessions for employees. These training sessions provide employees with the skills needed
                   to help adults, children and infants with respiratory and/or cardiac emergencies. The American Red
                   Cross Certification classes include a digital certificate, which is valid for two years, plus access to
                   digital learning materials and online refresher courses. The Firm also maintains first aid kits, medicine
                   cabinets and AED defibrillators at Starwood Capital Group offices.

                   In addition, Starwood Capital Group complies with ADA rules to provide a barrier-free workplace. To
                   this end, we operate handicapped-accessible bathrooms and elevators to ensure that all employees
                   can move freely and safely throughout our offices.

                                                                                                     THE CUBE, BERLIN, GERMANY
SOCIAL    15

    Maintain a Commitment to Diversity, Equity and Inclusion
    Starwood Capital Group’s Chairman & Starwood is deeply committed to fostering, cultivating and preserving
    a culture of diversity, equity and inclusion. The collective sum of the individual differences, life experiences,
    knowledge, inventiveness, innovation, self- expression, unique capabilities and talent that our employees
    invest in their work represents a significant part of not only our culture, but our reputation and company’s
    achievement as well.

    Starwood Capital Group’s Chairman & CEO, Barry Sternlicht, has demonstrated a commitment to diversity
    throughout his career and was granted the CEO Diversity Award by Diversity Best Practices/Business Women’s
    Network. As part of our drive to encourage diversity, equity and inclusion in the workplace, we have placed
    significant focus on developing meaningful external partnerships. Some examples include:

•	Signatory of ILPA’s Diversity in Action initiative.         •	Partnerships with InternX, The Robert Toigo
   The ILPA Diversity in Action initiative brings together        Foundation, TipStart, Harlem Capital Partners, and
   limited partners and general partners who share                The Posse Foundation, organizations that help match
   a commitment of advancing diversity, equity and                employers with candidates from diverse backgrounds
   inclusion in the private equity industry                    •	Partnered with iMentor, an external mentorship
•	Aim to increase minority and women hiring by                   opportunity for Starwood employees to commit
   posting open positions at historically black colleges          to helping high school students from low-income
   and universities (HBCUs) as well as at over 425                communities get to college through encouragement
   diversity groups across 58 college campuses                    to achieve their ambitions
   including Women in Real Estate Group (WIRE),                •	Partnered with Girls Inc., an organization which
   Association of Latino Professionals for America,               inspires all girls to be strong, smart, and bold through
   Harvard Undergraduate Women in Business                        life-changing programs and experiences that help
   (Sponsor), Black in Business at Brown, MIT Hispanic            girls navigate gender, economic, and social barriers
   Business Club, Wisconsin Graduate Women in
                                                               •	Partnered with Out Investors, a global network for
   Business, Cornell LGBTQ Business Alliance and
                                                                  LGBTQ investment professionals that’s mission is to
   many more
                                                                  make the direct investing industry more welcoming
•	Partnered with Year UP, an organization that                   for LGBTQ professionals by organizing networking
   provides internships for students from low-income              events, speaker series and mentorship programs
                                                               •	Launch partner of HIVE Diversity, a first of its kind
•	$500K commitment to support the PREA                           recruiting app that is designed to connect employers
   Foundation in partnership with Sponsors for                    with a community of students that represents a broad
   Educational Opportunity (SEO), a professional                  range of diversities
   development program, providing Black & Hispanic
                                                               •	Partnered with 100 Black Interns, which offers 100
   undergrads with internships
                                                                  internships in the investment management industry
•	Corporate sponsor of Point Foundation, the nation’s            to black students in the UK helping them kick start
   largest scholarship organization for LGBTQ scholars            their careers

    Starwood Capital recognizes that diversity alone is not enough; equal attention must be given to creating
    and cultivating an equitable and inclusive environment. All employees are required to complete an eLearning
    course on Unconscious Bias, which is designed to provide examples of how to continue to foster a diverse
    and inclusive environment. To do this, the course offers realistic, practical guidelines for creating an inclusive,
    respectful workplace. It also addresses some of diversity and inclusion’s biggest challenges, increases
    awareness of unintentional micro inequities, and offers learners tips for navigating these challenges.

                      Offer a Path to a Rewarding Career
                      As a world-renowned and highly respected private investment firm, Starwood Capital Group is the
                      ideal place for employees to build their careers. The Firm provides a wide range of work experiences
                      and learning opportunities with our various teams including: acquisitions, asset management,
                      investor relations, accounting, human resources and information technology. Starwood Capital
                      Group offers a challenging, fast-paced, collegial environment developed through teamwork and close
                      working relationships. Employees are given extensive responsibilities and are stretched intellectually.
                      We provide incoming analysts and summer interns with a comprehensive training program before
                      they report to their specific teams. We also offer our more experienced employees a catalog of
                      professional classes/training from LinkedIn Learning and other sources covering a range of topics and
                      subject matter that improves both technical and soft skills including: leadership and management,
                      public speaking, business writing, emotional intelligence, unconscious bias, Excel and other
                      applications. Our goal is to empower our professionals to exceed their own expectations. Equally
                      as important as professional development is personal development. We offer personal learning
                      opportunities on topics such as mindfulness, motivation and balance and send out weekly wellness
                      newsletters, which include fitness challenges, healthy recipes, and other health tips.

                      Foster a Culture of Meritocracy
                      Starwood Capital Group creates lucrative incentives for its employees to expand their careers and
                      advance in the organization through promotions and recognition of achievements. The Firm has more
                      than 100 partners, all of whom have a participation in the profits of the Firm’s funds. We believe that
                      sharing profits across a large and broad group of professionals encourages everyone to think and act
                      like owners, further aligns interests with our investors and maximizes overall fund returns.

                      At year-end, employees engage in a performance review process which includes a self-evaluation,
                      manager evaluation and 360-degree feedback. These reviews are a useful tool for reflecting on one’s
                      own performance and providing objective feedback to colleagues and managers. Self-evaluation
                      includes the opportunity to outline both short- and long-term career goals, as well as training and
                      development goals.

     Enrich the Lives of                             personal trainers to lead community
     Our Employees                                   on-site group workouts. In addition,
                                                     we offer a confidential Employee
     We are committed to the health and
                                                     Assistance Program to provide
     well-being of our employees. For
                                                     counseling services for employees and
     example, the Firm regularly sponsors
                                                     their families during difficult personal
     wellness competitions, which includes
                                                     times. We also offer an attractive
     complimentary workout classes at
                                                     benefits package including market
     boutique gyms including Soul Cycle,
                                                     competitive medical, dental and
     Barry’s Boot Camp and Equinox,
                                                     vision plans for physical wellness, and
     provides access to in-house flu shots
                                                     401k, life and disability insurance for
     and biometric testing, and provides
                                                     financial well-being.
SOCIAL        17

Best-In-Class Real Estate
Investment Firm
We are driven to maintain our position
as a world-class real estate (and other
alternatives) investment firm that
embraces values others may overlook,
while delivering superior results for our
clients through rigorous financial and
risk discipline.
To achieve this, we:
•	Create an ideal environment to
   attract talented people
•	Mentor, teach and provide support
   resources for our professionals to
   make successful investments
•	Focus on risk/reward analysis, with
   an emphasis on downside protection
   and capital preservation
•	Align our interests with those of our
   LPs, so our team thinks and acts like
•	Always do the right thing for our LPs,
   our communities and our world


                                                                          FOUR SEASONS RESORT AND RESIDENCES ANGUILLA, ANGUILLA, BWI

     Make a Positive Impact                         other issues to form a mutually           participated in various fundraisers
     On the Community                               beneficial relationship and ensure        and charitable programs nationally
                                                    the successful operation of the           and in our local markets for many
     By conducting in-depth market
                                                    hotel. Then, after Hurricane Irma         years. We have donated ~$100K
     research before entering any market,
                                                    struck the island in September 2017       over the years to the American Red
     Starwood Capital Group gains an
                                                    as a Category 5 hurricane—with            Cross, raised from our associates,
     understanding of the issues facing
                                                    sustained winds of 185 mph and            residents and vendors. We have
     the community, which then enables
                                                    gusts as high as 215 mph—we               also consistently engaged with the
     the Firm to make an informed
                                                    worked tirelessly and leveraged           U.S. Marine Toys for Tots program
     decision about whether to enter
                                                    relationships around the world to         and the Carter Blood Bank, as well
     the market and if so, to bring a
                                                    restore the resort. As a result of our    as provided labor, materials and
     better product to market to the
                                                    swift actions and dedication, we          donations for local projects organized
     benefit of the community and our
                                                    officially reopened the hotel in March    by our local apartment associations
     investors alike. Since our investments
                                                    2018—the first among the large            for the greater good of our neighbors,
     are generally in physical assets,
                                                    resorts that sustained major damage.      residents and overall communities.
     Starwood Capital Group maintains
                                                    In addition, we created and deployed      In addition, Starwood Capital Group
     a hands-on approach to all aspects
                                                    a major relief effort, Anguilla           supports nationwide programs such
     of asset management, including
                                                    Stronger, for employees of major          as #GiveHealthy online food drives
     community risks. Starwood Capital
                                                    resorts on the island, and raised over    and One Warm Coat drives and we
     Group regularly works closely with
                                                    $1.8M. The reopening of the hotel         created partnerships in our local
     the local community to ensure that
                                                    not only provided recovery of jobs        communities with organizations such
     our investments enhance the area.
                                                    but also increased awareness around       as Neighbor to Neighbor, Person
                                                    the world that the island and resort      to Person and Family Centers. Our
     For example, throughout the long
                                                    were operational which resulted in        activities with these organizations
     process of acquiring the Four
                                                    additional bookings for the remainder     include setting up a holiday toy store
     Seasons Anguilla (which made
                                                    of 2018 and beginning of 2019.            for families in need and gift wrapping
     Starwood Capital Group the island’s
                                                                                              selections, distributing frozen turkeys
     largest employer), the Firm worked
                                                    In addition, our multifamily property     for Thanksgiving meals, and working
     with the Anguillan government
                                                    management company (Highmark              with social services to adopt a family
     regarding taxes, employment and
                                                    Residential) and its associates have      for the holiday season.
SOCIAL     19

                Uphold High Standards for Our Service Providers
                We are committed to hiring contractors and service providers who compensate workers fairly
                and have a reputation for safety and dependability. It is also important to note that all large-
                scale procurement we do is competitively bid, and all of our successful bidders are obligated to
                comply with local, state and federal laws pertaining to wages, safety and building ordinances.
                For example, depending on the scope of work, most of our construction projects employ at least
                one fulltime OSHA-certified site safety person, and contractors must adhere to rigorous safety

                Starwood Capital Group seeks to have positive relationships with various unions. However,
                those relationships do not trump our fiduciary duty to our investors, who expect us to manage
                costs in an effort to increase profitability. Starwood Capital Group is neither pro-union nor anti-
                union: we simply try to find the most qualified workers for the best price, and every project is
                different depending on size, location and complexity of the job.

                While some of our construction projects are “open shop” (where employees are not required
                to join a labor union in order to be hired or continue working), we opt to build certain projects
                exclusively with union labor when the circumstances are appropriate.

Improve the Lives of Others
Starwood Capital Group Chairman & CEO Barry
Sternlicht is personally committed to “giving back,”
and this philosophy is woven into the fabric of the Firm.     services. Starwood Capital Group senior management
With ~4,100 employees in offices around the world,            facilitates corporate donations to foundations and
we have the intellectual capital, talent, and financial       charities, including Habitat for Humanity, the Breast
resources to band together and drive positive change to       Cancer Research Foundation, Big Brothers Big Sisters of
make a difference. Mr. Sternlicht’s humanitarian efforts      New York City, Nature Conservancy and City Harvest.
have garnered prestigious national honors such as             Employees are encouraged to volunteer for causes of
JDRF’s Man of the Year, JDRF’s Living and Giving Award        importance to them, including serving on non-profit
and JDRF’s Chairman’s Award.                                  boards.

Mr. Sternlicht serves on the Board and is the Former          On multiple occasions, Starwood Capital Group has
Chairman of The Robin Hood Foundation, New York               held company-wide community service days. For
largest poverty-fighting organization, which has              these days, we have partnered with City Harvest, a
distributed more than $3 billion to hundreds of New           food rescue organization dedicated to feeding the
York City-based soup kitchens, homeless shelters, day         city’s hungry men, women and children, and packed
care and senior citizen centers, schools, job training        thousands of pounds of produce for use in New York
programs, veteran programs, among other vital                 City like soup kitchens and food pantries.

                     At Starwood Capital Group, we work hard to meet the gold standard for strong
                     and ethical governance procedures that ensure we never conduct business that
                     could jeopardize our leading role in the investment community. We are guided by
                     the following principles:

                                    The Firm has adopted a comprehensive Code of Ethics that each employee is required to
                                    acknowledge. Employees must conduct themselves with honesty and integrity, bearing in
                                    mind that their conduct reflects on the Firm’s reputation. Employees must refrain from any
                                    activity that places or appears to place their interests ahead of the interests of the Firm’s
                                    advisory clients. Employees must also observe all applicable provisions of federal securities
                                    laws pertaining to their conduct and the Firm’s business.

                                    The Firm’s senior executives work to ensure compliance with all legal and regulatory
                                    requirements applicable to the assets managed on behalf of investors, including, but not
                                    limited to, the Foreign Corrupt Practices Act, U.K. Bribery Act, Pay to Play laws and other
                                    regulatory laws and statutes domestically and abroad. The Chief Compliance Officer and
                                    the General Counsel are responsible for overseeing the Firm’s regulatory obligations, and a
                                    dedicated insurance team is responsible for placing the proper insurance on all of our assets.
                                    In addition, each fund maintains an independent Advisory Committee comprised of LPs,
                                    whose review and approval is called for in certain instances where there may be a potential
                                    conflict of interest.

                                    We invest alongside our Limited Partners with personal money in every transaction, and we
                                    only collect our carried interest after our Limited Partners have received a full return of their
                                    capital as well as an attractive preferred return. Our opportunity funds take no acquisition,
                                    financing, disposition or advisory fees—which means that the General Partner does not
                                    profit from simply winning a bid. Further, we are guided by ethical behavior within the
                                    investment community. For example, for those funds affected by the 2008-2009 recession,
                                    the Firm voluntarily deferred collecting management fees (for several years) until the funds
                                    had adequate liquidity.

                                    The legal and compliance teams are responsible for performing background checks and
                                    other checks associated with standard Know Your Customer (KYC) diligence to verify the
                                    integrity and ascertain or confirm that Starwood Capital Group is dealing with responsible
                                    partners, counterparties and investors. Starwood Capital Group has a robust Anti-Money
                                    Laundering Policy that is designed to address the risks related to financing terrorist activities
                                    and criminal organizations. We always seek to comply with screening requirements, such as
                                    those set forth in various treasury regulations (such as the Patriot Act).
GOVERNANCE          21

                      The Firm’s regulatory counsel is responsible for including provisions related to OFAC,
                      specially designated nations, the investment advisors act of 1940 and other regulatory
                      requirements. The attorneys at Starwood Capital Group’s lead outside counsel, Rinaldi,
                      Finkelstein and Franklin LLC, have been representing Starwood Capital Group for more
                      than 25 years and are deeply familiar with the standard legal protections the Firm requires.

                      Starwood Capital Group has implemented a comprehensive reporting package that
                      provides not only the standard GAAP financial statements, but also some of the industry’s
                      most comprehensive Fund quarterly reports—that include detailed information on
                      portfolio activity and major investments as well as mark-to-market and projected internal
                      rates of returns, U.S. dollar profits and multiples for every investment.

                      The Firm maintains a comprehensive Compliance Manual that includes rules related to,
                      among other things, conflicts of interest, personal trading, gifts and entertainment and
                      political donations. All employees must acknowledge the Compliance Manual in writing
                      upon becoming an employee of the Firm and each year thereafter. Employees are also
                      subject to a variety of compliance procedures, including personal trade monitoring, and
                      if applicable, training with respect to the Foreign Corrupt Practices Act and the U.K.
                      Bribery Act. Due to the constantly changing nature of the regulations applicable to the
                      Firm, the Chief Compliance Officer evaluates new regulations and changes to existing
                      regulations, and undertakes appropriate steps within the Firm to ensure compliance. The
                      Firm’s Compliance Manual is updated annually to reflect new or changed regulations. The
                      Firm has strict policies and procedures relating to personal trading and investing which is
                      covered in our Compliance Manual. Among other things, Starwood Capital Group requires
                      employees to pre-clear investments in real estate, hotel and gaming companies, as well
                      as investments in private offerings. Starwood Capital Group also uses ComplySci to assist
                      with personal trade monitoring.

                      Starwood Capital is a signatory to the United Nations-supported Principals for Responsive
SUPPORT AND ADHERE    Investing (PRI) as we hope to contribute to developing a more sustainable global financial
TO THE UNPRI AND      system. The Firm has also endorsed the ILPA Private Equity Principles, which outline
ILPA PRIVATE EQUITY   a number of key principles to enhance the partnership between Limited Partners and
PRINCIPLES            General Partners, with the goal of improving the private equity industry for the long-term
                      benefit of all its participants.

                    Starwood Capital Group’s longstanding
                    relationships with its investors, business partners
                    and lenders are a testament to our success
                    in meeting the highest standard of fairness,
                    cooperation, transparency and commitment to the
                    communities in which we operate.
CONCLUSION        23


Miami                                   Chicago                                 New York
1601 Washington Avenue, Suite 800       One East Wacker Drive, Suite 3600       40 10th Ave 8th Floor
Miami Beach, FL 33139                   Chicago, IL 60601                       New York, NY 10014
Phone: 305.695.5200                     Phone: 312.242.3200                     Phone: 203.422.8101

Arlington                               Dallas                                  San Francisco
1525 Wilson Boulevard, Suite 825        5429 LBJ Freeway, Suite 800             100 Pine Street, Suite 3000
Arlington, VA 22209                     Dallas, Texas 75240                     San Francisco, CA 94111
Phone: 877.648.3235                     Phone: 214.561.1200                     Phone: 415.247.1220

Atlanta                                 Greenwich, CT                           Washington, D.C.
400 Galleria Parkway, Suite 1450        591 West Putnam Avenue                  1255 23rd Street NW, Suite 250
Atlanta, GA 30339                       Greenwich, CT 06830                     Washington, D.C. 20037
Phone: 770.541.9046                     Phone: 203.422.7700                     Phone: 202.507.6710

                                        Los Angeles
                                        11601 Wilshire Blvd, Suite 420
                                        Los Angeles, CA 90025
                                        Phone: 310.893.2781

EUROPE                                  ASIA & AUSTRALIA

London                                  Hong Kong
1 Eagle Place, 2nd Floor                Somptueux Central, 20/F
St. James’s                             52-54 Wellington Street
London, SW1Y 6AF                        Hong Kong
United Kingdom                          Phone: +852.3792.0349
Phone: +
Luxembourg                              Level 4 Keyakizaka Terrace
2-4 rue Eugène Ruppert                  6-15-1 Roppongi, Minato-ku
L-2453 Luxembourg                       Tokyo 106-0032 Japan
Phone: +352.
Amsterdam                               Level 32, Suite 2334
Beechavenue 54                          200 George Street
1119 PW Schiphol-Rijk                   Sydney NSW 2000
The Netherlands                         Phone: +61 282 774 126
Phone: +31.20.658.65.20

For investor relations inquiries, please contact: starwoodInvestorRelations@starwood.com
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