Environmental, Social and Governance (ESG) Policy
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Environmental, Social and Governance (ESG) Policy
2 ENVIRONMENTAL, SOCIAL AND GOVERNANCE (ESG) POLICY
1 HOTEL WEST HOLLYWOOD
WEST HOLLYWOOD, CA
INTRODUCTION 3 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.
4 ENVIRONMENTAL, SOCIAL AND GOVERNANCE (ESG) POLICY
ENVIRONMENTAL
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.
SUPPORT SUSTAINABLE OFFICES AND RESIDENTIAL PROPERTIES
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:
THE VISIONAIRE, NEW YORK, NY ONE UNION STATION, DENVER, CO T-MOBILE OFFICE PARK,
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 5
ENERGY PARK, MILAN, ITALY
T-MOBILE OFFICE PARK, WARSAW, POLAND ONE UNION STATION, DENVER, CO THE VISIONAIRE, NEW YORK, NY
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
ST VINCENT PLAZA, GLASGOW, SCOTLAND SEAMARK BUILDING (ELM PARK), ST LEONARDS, SYDNEY, AUSTRALIA
DUBLIN, IRELAND
6 ENVIRONMENTAL, SOCIAL AND GOVERNANCE (ESG) POLICY
INDUSTRY LEADER IN ENVIRONMENTALLY CONSCIOUS HOSPITALITY
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.
1 HOTEL BROOKLYN BRIDGE, BROOKLYN, NY
ENVIRONMENTAL 7
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:
THE FUNDAMENTAL START MATERIAL RE-USE AND
• 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)
SITE DESIGN AND
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
WATER MANAGEMENT
• 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
suppliers.
• Variable Speed Drives on Mechanical
Systems
8 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
building
• 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 9
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
HILTON GARDEN INN WASHINGTON, D.C./ the ocean.
GEORGETOWN, WASHINGTON, D.C.
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.
10 ENVIRONMENTAL, SOCIAL AND GOVERNANCE (ESG) POLICY
BUCK LAKE, HARMONY, FL
TERRAMOR, TEMESCAL VALLEY, CAENVIRONMENTAL 11
RESPECT FOR THE LAND
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.
• MORE
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.
• IRRIGATION CONTROLS ON PUBLIC AND
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.12 ENVIRONMENTAL, SOCIAL AND GOVERNANCE (ESG) POLICY
SPEARHEAD THE SHIFT TOWARD CLEAN ENERGY PRODUCTION
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.13
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, TX14 ENVIRONMENTAL, SOCIAL AND GOVERNANCE (ESG) POLICY
SOCIAL
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, GERMANYSOCIAL 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
communities
• 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.16 ENVIRONMENTAL, SOCIAL AND GOVERNANCE (ESG) POLICY
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
principals
• Always do the right thing for our LPs,
our communities and our world
ONE ATLANTIC CENTER, ATLANTA, GA18 ENVIRONMENTAL, SOCIAL AND GOVERNANCE (ESG) POLICY
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
standards.
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.20 ENVIRONMENTAL, SOCIAL AND GOVERNANCE (ESG) POLICY
GOVERNANCE
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
CONDUCT BUSINESS
mind that their conduct reflects on the Firm’s reputation. Employees must refrain from any
FAIRLY, OBSERVING A
activity that places or appears to place their interests ahead of the interests of the Firm’s
STRONG CODE OF ETHICS
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
ALIGN OUR INTERESTS
capital as well as an attractive preferred return. Our opportunity funds take no acquisition,
WITH THOSE OF OUR
financing, disposition or advisory fees—which means that the General Partner does not
PARTNERS
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
WORK WITH
integrity and ascertain or confirm that Starwood Capital Group is dealing with responsible
RESPONSIBLE PARTNERS
partners, counterparties and investors. Starwood Capital Group has a robust Anti-Money
AND COUNTERPARTIES
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
OPERATE WITH
most comprehensive Fund quarterly reports—that include detailed information on
TRANSPARENCY
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
WORK WITHIN A
political donations. All employees must acknowledge the Compliance Manual in writing
COMPLIANCE CULTURE
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.22 ENVIRONMENTAL, SOCIAL AND GOVERNANCE (ESG) POLICY
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 SOUTH BANK CENTRAL LONDON, ENGLAND
NORTH AMERICA
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: +44.207.016.3650
Tokyo
Luxembourg Level 4 Keyakizaka Terrace
2-4 rue Eugène Ruppert 6-15-1 Roppongi, Minato-ku
L-2453 Luxembourg Tokyo 106-0032 Japan
Phone: +352.26.64.51.21
Sydney
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.comYou can also read
