ESG Policy

1. Introduction

Starlight Group Property Holdings Inc. (together with its affiliates, “Starlight”) maintains an Environmental, Sustainability and Social Policy (the “Policy”) to promote environmental and other responsible practices for the benefit of our employees, tenants, stakeholders and the communities in which we operate. Starlight conducts and will grow its business in a manner that respects the environment and strives to protect and conserve our world’s natural resources. For the purposes of this Policy, the term “employee” shall be deemed to include employees of Starlight, individuals retained by Starlight for services and any third party property management companies that contract directly with Starlight and render services to Starlight.

2. Scope

This Policy applies to all employees, vendors, third-party property managers and stakeholders. All parties are expected to comply with this Policy.

3. Values

Starlight works toward continuous improvement through the development and implementation of programs designed to address the environmental cost and impact of our activities, products and services. Starlight will:

  • Comply with applicable municipal, provincial and federal legislation;
  • Reduce and minimize our utility and energy consumption;
  • Perform environmental benchmarking of assets with comparable assets of similar geographic location and demographics;
  • Use materials and energy efficiently to conserve natural resources;
  • Minimize the emissions that contribute to climate change;
  • Develop relationships and collaborate with our community, suppliers, contractors, government agencies, and other organizations engaged in improving the environment;
  • Review environmental objectives and monitor performance, to continually improve our environmental strategy and targets;
  • Encourage construction partners to minimize construction waste and recycle materials; and
  • Require employees to participate in training and professional development programs.

4. A Greener Building

Through the implementation of energy efficient programs, green technologies and sustainability strategies in buildings, Starlight aims to reduce its carbon footprint and minimize greenhouse emissions.


Environmental Technology

Starlight is committed to exploring new environmental technologies which allow Starlight to reduce its energy consumption and minimize the environmental impact of its business operations through capital upgrades to new energy efficient equipment such as chiller, boilers etc. Starlight employs technologies such as Electric Vehicle Charging Stations and Renewable Energy Technologies to further this commitment.

Waste Diversion

Starlight is committed to investigating opportunities in new and existing assets to reduce the amount of waste that is generated and redirect from landfills. Starlight engages third party property managers and tenants in best practices for recycling and waste diversion. Starlight supports government initiatives to reduce its waste products and separate products into recycling streams.

Reduce Utility Consumption

Starlight is committed to lowering utility consumption in its buildings through implementing energy and utility retrofits using energy and water-efficient technologies.

Green Products and Services

Starlight encourages third-party property management companies and all vendors to use green products that are less harmful and toxic to the environment.

Education and Promotion

Starlight educates its stakeholders and tenants in green initiatives and environmental programs which have been or will be implemented throughout its buildings.

Risk

Starlight follows all applicable laws and evaluates the environmental risks associated with its properties and business operations. Starlight will continue to manage risk through hazard identification, incident management and corrective measures, as outlined in the Health and Safety Management System. Identified risks will be monitored, reviewed and updated according to municipal, provincial and federal regulations.

Green Building Certifications

Starlight will continue evaluating the feasibility of having its buildings certified for LEED and BOMA certifications as well as new certifications when introduced. Starlight undertakes and implements a wide number of energy conservation measures as part of its overall certification process.

5. Monitoring and Tracking

Starlight continually tracks and monitors utility consumption and cost. Tracking and monitoring consumption allows Starlight to review the overall consumption and ensure the correct rates and consumption are being processed. Starlight tracks the metrics of implemented energy savings programs on a regular basis to ensure savings are being achieved. Starlight benchmarks new and


existing buildings against similar building types and in a comparable geography to not only measure the success of its implemented programs but to target buildings with a high utility consumption.

6. Community Engagement

Starlight organizes and participates in various community events pertaining to a wide range of causes relating to environmental, social and charity. Starlight is committed to attending events pertaining to the environment and energy sectors within the real-estate industry.

7. Social

Starlight conducts its business operations with corporate social responsibility in mind. This is accomplished through conducting business in a socially responsible and ethical manner, supporting human rights and engaging, learning from and respecting the communities and cultures in which Starlight operates. Starlight leaders ensure that appropriate organizational structures are in place to effectively identify, monitor and manage corporate social responsibility.

8. Health and Safety

Starlight has an established Health and Safety Management system (the “System”), based on OHSAS 18001. The System is comprised of multiple components which formulate Starlight’s strategy for ensuring health and safety in the workplace. These components include: planning, implementation, corrective actions and management review.

At the planning stage of the System, management and leadership are committed to planning for situations that have the potential to have an adverse effect on the health and safety of employees. A health and safety plan is devised that meets all regulatory requirements. The plan incorporates hazard identification and risk assessments, which are conducted prior to the implementation of the plan.

In the implementation and operations stage, resources are allocated to health and safety related initiatives. All processes are documented, provisions are made for emergency planning, employees are educated in emergency response planning and contractors are managed and trained to mitigate risk. Health and safety is a prerequisite for Starlight’s contractors, vendors and third party property management companies. Contractors are evaluated for their compliance with Starlight’s health and safety guidelines.

After implementation, Starlight audits and evaluates the plan and corrects any issues that may have occurred that resulted in an incident and measures the performance of contractors and vendors. Management reviews the System on an ongoing basis and seeks out ways to improve upon it.

9. Environmental, Sustainability and Social Programs

Environmental Programs

Starlight employs numerous environmental programs to improve the efficiency and reduce the carbon footprint of its properties. To conserve water and electricity, Starlight retrofits high consumption toilets, showerheads and faucet aerators and implements lighting upgrades and controls, carbon monoxide system optimization, electric heating, voltage harmonizers, cooling equipment, sub-metering, electrical vehicle charging stations and co-generation at its properties. In addition, mechanical upgrades have


been made which include boiler plant upgrades and replacement, building automation systems and reflector panels.

In order to reduce the amount of waste that each property produces, waste diversion strategies have been undertaken in the way of waste equipment optimization, remote compactor monitoring, tenant engagement/education programs and diversion of construction materials such as structural steel, rebar, railing and concrete.

Sustainability Programs

Starlight’s Sustainability Committee is responsible for workplace education on green initiatives pertaining to energy, water use, waste generation and diversion within Starlight’s corporate office. Starlight’s achievements include organics and battery recycling programs. To date, the committee has successfully organized park cleanups and fundraising for the environmental charity World Wildlife Fund. The Sustainability Committee meets regularly to update Starlight on goals and set new targets. Knowledge and awareness gained from the work environment are often transferred to our communities and our lives at home. Starlight organizes and participates in community events pertaining to environmental awareness and outreach by holding ‘Environmental Day’ events.

Social Programs

Employees actively participate in giving back to charitable organizations throughout the year. Some prior highlighted social programs include: The Daily Bread Food Bank, Princess Margaret Run/Walk, World Wildlife Fun, CN Tower Climb, Children’s Wish Foundation, Ronald McDonald House Charity and the Holiday Helper’s Charity.

10. Roles and Responsibilities

Starlight’s executive leadership team is responsible for developing environmental and sustainability procedures in order to implement policies which govern Starlight’s activities in this area. Starlight’s Executive Director of Procurement and Technical Services executes the aforementioned procedures and monitors their progress and success.

Starlight also employs energy project managers to review the performance of utility consumption at its properties. Findings are reported to the executive leadership team and improvements are made where necessary.

11. Approval and Review

This policy is reviewed annually by the Executive Director of Procurement and Technical Services. All recommended changes will be forwarded to the Chief Executive Officer for final review and approval.

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