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Global Company Disclosures

Information & Data Regulation

Regulated and Non-Regulated Businesses

Green Street Advisors, LLC is a U.S. limited liability company doing business as Green Street. The US Advisory business unit at Green Street is a state registered investment adviser and only offers US Advisory services through our California location. While Green Street offers some regulated products and services, global Research, Data and Analytics products along with Green Street’s global News publications are not provided as an investment advisor nor in the capacity of a fiduciary.

Green Street Advisors (UK) Ltd., doing business as Green Street, is authorised and regulated by the Financial Conduct Authority (FRN 482269). Our global organization maintains information barriers to ensure the independence of and distinction between our non-regulated and regulated businesses.

State of California Data Privacy Policies

We do not SELL or SHARE consumers’ information per the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA), or the General Data Protection Regulation (GDPR), but may collect personal information from you for specified business purposes.

European Union Data Privacy Policies

Green Street adheres to the EU-U.S. DPF Principles with regard to personal data transferred from the European Union and the United Kingdom and the Swiss-U.S. DPF Principles with regard to personal data transferred from Switzerland. For more information regarding your data privacy and how we process your personal information, please read our Global Privacy Policy and Disclosures.

Green Street processes the personal data of individuals in the European Union and European Economic Area and appoints our Locatus B.V. Netherlands office as our Data Protection Representative for the purposes of GDPR. If you would like to raise a question or exercise your rights in respect to your personal data, please refer to Green Street’s Privacy Policy for instructions.

Product Specific Disclosures

Sales Comps

All verified transactions in the Sales Comp database have been comprehensively reviewed by a trained Data Associate who consults and vets all available sources to construct an accurate record of each sale.

Forecasting and Predictive Analytics

The Green Street Forecasting tool is an estimation of future events based on market trends in historical data that have proved to provide actionable insights during past market cycles.

Green Street makes no representations or warranties as to any future performance of such metrics under any market cycles.

AVM Pro

AVM accuracy is substantiated by the back-testing results of the methodology white paper. For more details please request Green Street’s AVM Whitepaper. This is not part of Green Street’s regulated business.

IJ Global

While Green Street offers some regulated products and services, global Research, Data and Analytics products along with Green Street’s global News publications are not provided as an investment advisor nor in the capacity of a fiduciary. IJGlobal products are not part of a regulated Green Street business. Green Street’s global organization maintains information barriers to ensure the independence of and distinction between its non-regulated businesses

Advisory Services

Green Street US Advisory Services is regulated by the California Department of Financial Protection and Innovation, and its headquarters is located at 100 Bayview Circle, Suite 400, Newport Beach, CA 92660. Green Street Advisors (UK) Ltd., is authorised and regulated by the Financial Conduct Authority (FRN 482269). Services are only offered to clients or perspective clients where Green Street and its advisory services representatives are properly licenced or exempt from licensure. Please note, while Green Street offers some regulated products and services, global Research, Data and Analytics products along with Green Street’s global News publications are not provided as an investment advisor nor in the capacity of a fiduciary. The firm maintains information barriers to ensure the independence of its non-regulated businesses from the regulated services provided by Green Street.

Green Street Advisory Services, at times, assists Eastdil Secured, a real estate brokerage and investment bank, when Eastdil Secured provides investment banking services to companies in Green Street’s coverage universe. Green Street is never part of the underwriting syndicate or the selling group, but Green Street may receive compensation from Eastdil Secured for consulting services that Green Street provides to Eastdil Secured related to Eastdil Secured’s investment banking services. Green Street does not control, have ownership in, or make any business or investment decisions for, Eastdil Secured.

Content Specific Disclosures

Testimonials

All testimonials are for our Research, Data and Analytics products and not endorsements of our regulated Advisory practice. All testimonials have been provided by Green Street clients. No compensation has been exchanged.

Research Reports

Green Street Research, Data and Analytics products do NOT constitute investment advice, nor are they provided in the capacity of a fiduciary.

The information contained in research reports is based on data obtained from sources we deem to be reliable; it is not guaranteed as to accuracy and does not purport to be complete. Reports are produced solely for informational purposes and is not intended to be used as the primary basis of investment decisions. Because of individual client requirements, it is not, and it should not be construed as, advice designed to meet the particular investment needs of any investor. Reports are not an offer or the solicitation of an offer to sell or buy any security.

A number of companies covered by Green Street research reports pay an annual fee to receive Green Street’s research reports. Green Street may periodically solicit this business from the subject companies. In the aggregate, annual fees for Green Street US and Green Street UK research reports received from subject companies represent approximately 3% of each of Green Street US and Green Street UK respective total revenues.

Green Street publishes research reports covering issuers that may offer and sell securities in an initial or secondary offering.

Green Street US generally prohibits research analysts from sending draft research reports to subject companies. However, it should be presumed that the analyst(s) who authored this report has(/have) had discussions with the subject company to ensure factual accuracy prior to publication and has(/have) had assistance from the company in conducting due diligence, including visits to company sites and meetings with company management and other representatives.

Reports issued in the European Economic Area (EEA) by Green Street UK: Green Street US accepts no responsibility for this report to the extent that it is read by persons based in the EEA. Green Street Advisors (UK) Ltd is registered in England, (Company number. 6471304), and its registered office is 3rd and 4th Floors, 25 Maddox Street London W1S 2QN. Green Street Advisors (UK) Ltd is authorised and regulated by the Financial Conduct Authority in the United Kingdom (FRN 482269).
Green Street US is the parent company of Green Street UK.

Green Street US relies on the Limited Connection Relief for services provided to our clients located in Australia.
Green Street UK is exempt from the requirement to hold an Australian financial services licence under the Act in respect of the financial services; and is regulated by the FCA under UK laws, which differ from Australian laws.

Green Street, along with its research professionals, are not registered as an advisor or dealer in any category with a securities regulator in Canada and any advice provided is not a solicitation to offer or sell or trade in specific securities or to provide tailored advice to any person in Canada.
Swiss recipients: the funds, the REITs, the investment companies, and any collective investment schemes referred to in these reports may not have been registered with the Swiss Financial Market Supervisory Authority (FINMA) and no Swiss representative or paying agent has been appointed. Reports provided in Switzerland are for the use of the addressees only and may not be distributed, copied, reproduced, or passed on to any third parties.

Terms of Use

Protection of Proprietary Rights: To the extent that this report is issued by Green Street US, this material is the proprietary and confidential information of Green Street and is protected by copyright. To the extent that this report is issued by Green Street UK, this material is the proprietary and confidential information of Green Street (UK) Ltd and is protected by copyright.

Reports may be used solely for reference for internal business purposes. Reports may not be reproduced, re-distributed, sold, lent, licenced, or otherwise transferred without the prior consent of Green Street. All other rights with respect to research reports are reserved by Green Street.

EEA and UK Recipients: For use only by Professional Clients and Eligible Counterparties: Green Street Advisors (UK) Ltd is authorised by the Financial Conduct Authority to issue this report to “Professional Clients” and “Eligible Counterparties” only. This report is not for the use of “Retail Clients”. This report is provided in the United Kingdom for the use of the addressees any other person who receives this report should not act on the contents of this report.

Green Street reserves the right to update the disclosures and policies set out in this document at any time.

ESG Policy and Metrics

Green Street renumeration considerations are subject to compliance with all Green Street policies including its ESG Policy.

Green Street considers sustainability factors in its research recommendations. Green Street has built a way to assess the “E” of ESG by rating with an “E” REIT Score. A variety of metrics, “E” metrics, have been created to assist investors in discerning differences across companies. These measures are not intended to find the most sustainable or “greenest” investment, but rather where the potential risks/opportunities may be and not factored into pricing. These “E” metrics, while important, appear to have little impact on overall intrasector REIT valuation differences. REITs tend to look very similar, which limits the ability to pick stocks based on “E”. The “E” issue matters far more between property sectors and between Class A and Class B properties. Thus, it’s not currently a big driver of Green Street stock picks, but will likely influence our thoughts between high vs low quality buildings more dramatically in the future. Green Street also examines corporate governance factors in its research recommendations. A corporate governance score has been utilised for U.S. REITs that helps inform the alignment between management, the board, and shareholders on a variety of metrics. This corporate governance score and other aspects of governance are not formal components of Green Street’s REIT valuation model, but it provides another factor with which to differentiate between REITs.

Green Street does not take into account Principle Adverse Impacts (PAIs) in its investment advice on REITs. However, there are two areas in which limited considerations involving climate events are factored into our process: market‐level long‐term growth rates account for climate events while sector allocation results are impacted either by an adjustment to risks factors or to capitalised expenditures to quantify the cost of a possible transition to net zero emission. Overall this is a very small part of our research process. In addition, since we cover public companies that operate under their own level of regulation, were an issue at a covered company made public, this would be considered and opined upon as appropriate.

Environmental, Social, and Governance Policy (ESG)

Introduction and Scope
Below is a set of principles and practices that guide Green Street’s operations to align actions with ESG goals. This policy applies to all business activities conducted by or on behalf of the Green Street global organization.

Overall, we consider social, ethical, and environmental issues in a manner consistent with our duties to our employees, clients, and owners and to be accessible to, and engage with, a range of stakeholders on key ESG issues and challenges.

Thought Leadership on this topic ensures we take the analytical lead as innovators in Commercial Real Estate on topics related to ESG that impact the industry and the environment.

Employee Engagement is important as we implement relevant and appropriate ESG training, awareness for employees to better enable our team to make a difference through changes in behavior, and changes to company practices and policies.

Diversity and Inclusion is paramount to our organization as we identify, recruit, and develop the best talent in the market regardless of gender, race, ethnicity, nationality, religion, orientation, or other background. We celebrate the diversity of our employees, and we work continuously to create an environment where the best talent can contribute, learn, grow, and succeed regardless of differences.

Suppliers are expected to adhere to the same principles and ethical standards set by Green Street throughout the course of our business relationships. Where relevant and appropriate, we will seek partnerships with suppliers that are owned, operated, or managed by traditionally underrepresented groups.
Environmental Sustainability
We are committed to driving down our energy and carbon impacts. Our program is committed to environmentally sustainable initiatives that deliver near-term efficiency, value and health for our business, our people, and the wider community.
Social

Green Street understands the importance of meeting its social obligations both at the company level and in the communities where we do business. Green Street is committed to engage with our employees to provide a challenging, dynamic, and inclusive work environment that supports their professional development, and promotes a work-life balance that prioritises overall health and wellness. We will support initiatives that benefit the local and macro environment, human welfare, and education. We will preserve and promote the protection of human rights and welfare within our own business activities, as well as those of our supply chain.

Governance

Our focus is to promote strong oversight, transparency, and risk management at all levels of our organization, ensuring the resilience and long-term preservation of value for our business.

Employment Related Policies & Disclosures

Managing Conflicts of Interest

Conflicts of interest can seriously impinge the ability of Green Street employees to do their job. In that spirit, Green Street adheres to the following policies across its organization regarding conflicts of interest:
Green Street employees are prohibited from actively trading the shares of any company in our coverage universe.

Green Street employees do not serve as officers or directors of any of our subject companies.
Neither Green Street nor its employees/analysts receive any compensation from subject companies for inclusion in our research.

On occasion, Green Street analysts may be contacted by companies within the firm’s coverage universe regarding potential employment opportunities. Additional disclosure will be made when appropriate.

Green Street’s Advisory business services investors seeking to acquire interests in publicly traded companies. Green Street may provide valuation services to prospective acquirers of companies which are the subject(s) of Green Street’s research reports.

Modern Slavery and Human Trafficking Policy

Background

This Global Modern Slavery and Human Trafficking Policy considers the requirements of the Modern Slavery Act 2015 (‘Act’) and the “Transparency in Supply Chains etc. A Practical Guide” and other similar global laws that address the regulation of human rights. The Act makes provisions regarding slavery, servitude, forced or compulsory labour, and human trafficking, including provisions for the protections of victims thereof.

Application

This Policy relates to the Green Street organization as a whole. The policy applies to all persons working for the Green Street group or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, interns, agents, contractors, and suppliers.

Organisational Structure

The Green Street organization currently has offices in London (UK), California, New York and New Jersey, Canada, Australia, Bulgaria and the Netherlands operating predominantly in the EEA and United States. Originally established in the United States in 1985, the UK branch has operated in London for over 15 years and is owned and managed by Green Street Advisors, LLC, headquartered in the U.S. Green Street’s global presence has expanded through acquisitions and strategic growth initiatives that began in 2021. We operate in the financial services sector providing research, data and news.

Definition

Green Street considers modern slavery to be:
  • Human Trafficking;
  • Child labour;
  • Forced labour, through mental or physical threat;
  • Bond labour, where people borrow money that they cannot afford to repay and must then work to pay off the debt;
  • Being owned or controlled by an employer through mental or physical abuse or the threat thereof;
  • Being dehumanised, treated as a commodity or being bought or sold as property;
  • Being physically restrained or to have any restriction placed on freedom of movement.
  • Not being paid for work carried out or at a level objectively considered unfair.
This list is non-exhaustive.

Statement

Green Street recognises that modern slavery is a crime and a violation of fundamental human rights. It may take many forms, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Green Street acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions laid down in the Act and any subsequent legislation in this regard. The company strictly prohibits the use of modern slavery and human trafficking in all our operations and supply chain. We have been and will continue to be committed to operating our systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. Green Street understands that this requires an ongoing review of both its internal practices and outside vendor relationships.

We do not enter into business with any other organisation, in the UK or abroad, which knowingly supports or is found to involve itself in slavery, servitude, forced or compulsory labour. We expect that our suppliers will hold their own suppliers to the same high standard.

No labour provided to Green Street in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The company strictly adheres to all standards required in relation to its responsibilities under relevant employment legislation in the UK and the United States.

The prevention, detection and reporting of modern slavery in any part of our company or supply chain is the responsibility of all those working for us or on our behalf. Employees must not engage in, facilitate, or fail to report any activity that might lead to, or suggest, a breach of this statement.

Supply Chains

Green Street has a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships. We expect all those in our supply chain as well as third party vendors to comply with our values in this respect. We furthermore expect that our suppliers will hold their own suppliers to the same high standards.

Potential Exposure

Green Street considers its risk of exposure to slavery/human trafficking to be extremely limited. It does not conduct business or engages routinely with any suppliers in high-risk geographies or industries. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it. When engaging in jurisdictions with a potential higher risk, enhanced due diligence procedures are carried out and documented in full as part of its vendor diligence process.

Commitments/Due Diligence

The company carries out due diligence in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains. For this purpose, the company has set out Vendor Management Due Diligence Policy and procedures.

The company has not, to the best of its knowledge, conducted any business with any organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, Green Street has taken the following steps to ensure that modern slavery is not taking place:

We have systems in place to encourage the reporting of concerns and the protection of Whistle-blowers.
Where possible we build longstanding relationships with suppliers and make clear our expectations of business conduct. We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.

With regards to national or international supply chains, our point of contact is preferably with a UK or European company, where applicable we expect these organisations to have appropriate anti-slavery and human trafficking policies and processes in place.

If we find that individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action. Any such action will focus on finding the most desirable outcome for those negatively impacted by the breach.

Any internal breach of this policy may result in disciplinary action being taken.

Key Performance Indicators

Green Street has set out the following key performance indicators to measure its effectiveness in ensuring moderns slavery is not taking place in the company or its supply chain:
  • Always ensure that the minimum employment age is adhered to in line with relevant legislation.
  • Ensure that the relevant ‘right to work’ checks are duly completed.
  • Always apply at least national minimum wage thresholds in line with relevant legislation.
  • All employee salaries are paid into a bank account bearing that employee’s name.
  • Ensure regular contact with material suppliers and critical outsourcers including their understanding of, and compliance with, our expectations.
  • Ensure relevant staff members receive appropriate training during their induction period and ongoing when required.
  • Regularly review this policy and reassess our potential exposure. If required, monitor potential risk areas identified in our supply chain.
  • Always ensure that the minimum employment age is adhered to in line with relevant legislation.
  • Ensure that the relevant ‘right to work’ checks are duly completed.
  • Always apply at least national minimum wage thresholds in line with relevant legislation.
  • All employee salaries are paid into a bank account bearing that employee’s name.
  • Ensure regular contact with material suppliers and critical outsourcers including their understanding of, and compliance with, our expectations.
  • Ensure relevant staff members receive appropriate training during their induction period and ongoing when required.
Green Street has set out the following key performance indicators to measure its effectiveness in ensuring moderns slavery is not taking place in the company or its supply chain:

Regularly review this policy and reassess our potential exposure. If required, monitor potential risk areas identified in our supply chain.

Training

All Green Street employees are trained at initial onboarding and annually thereafter. This training is mandatory and attendance is recorded and retained in the firm’s books and records.

Related Policies

Whistleblowing Policy
Anti-Bribery and Corruption Policy
Recruitment and Selection Policy
Vendor Management Policy

Compliance

The Compliance Department should be contacted with regards to any concerns in relation to modern slavery. They will undertake appropriate action when required.

Questions may be directed to Compliance-UK@greenstreet.com.

This policy reflects the requirements set out in Section 54(1) of the Modern Slavery Act 2015 along with other relevant legislation and will be reviewed at least annually.

Responsibility for Policy

Green Street’s Board of Directors has overall responsibility for this policy.
Legal and Compliance has primary and day-to-day responsibility for implementing and reviewing this policy as well as dealing with any queries.

Outside Recruiting Agency Engagement

We stand firm in our commitment to never discriminate against any candidate or employee based on age, race, religion, color, ethnicity, national origin, gender, gender identity, sexual orientation, membership in an employee organization, medical condition, family history, genetic information, veteran status, marital status, parental status or pregnancy. We celebrate the unique qualities that each individual brings to an organization, fostering an environment where everyone feels valued and empowered.

Equal Employment Opportunity Employer

The talent acquisition team at Green Street will not ask for any personal identifying information such as your social security number, birth certificate, financial institution, driver’s licence number or passport information over the phone or over email during the interview process. We always schedule video interviews through Microsoft Teams, we do not require you to install any applications to your computer and we do not use chat services for interviews. Our recruiters only send emails from @greenstreet.com addresses. Up to date job openings can be found on our career site and all applications will go through the applicant tracking system (ATS) for review by the talent acquisition team. The Federal Trade Commission offers information on job scams and how to protect yourself here.

Recruiting Fraud Notice

Our team does not accept unsolicited resumes or CVs from recruiters or employment agencies. We will not pay referral compensation or recruiter fees associated with unsolicited resumes or CVs. The company expressly retains the right to consider and hire candidates from such submissions without incurring any financial obligation to the recruiter or agency involved.

AI-Assisted Hiring Process

We leverage artificial intelligence (AI) to enhance our hiring process, ensuring efficiency, consistency, and fairness in candidate evaluations. AI tools may be used in various stages, including resume screening, application processing, and interview scheduling. Please note that AI does not make final hiring decisions – our recruitment team carefully reviews and assesses all candidates. We are committed to maintaining transparency and fairness.

Career Accessibility

We endeavor to ensure that the opportunity to join us is accessible to individuals with diverse needs. Your journey is important to us, and we are dedicated to providing the support you need. If you wish to discuss potential accommodations related to applying for employment at Green Street or wish to provide feedback about the accessibility of this website, please contact careers@greenstreet.com.