Responsible Investment Policy

Frogmore’s approach to Responsible Investment

Frogmore’s focus is to achieve attractive, risk-adjusted returns by investing across property types throughout the UK. We acquire obsolete, mismanaged and/or mispriced assets and create value through hands-on asset management and selective development.

A commitment to responsible investment is part of Frogmore’s values and principles and is central to our philosophy of doing ‘Property, Properly’. Our approach to integrating ESG considerations in property investments is underpinned by our guiding principles of creating:

  • Exemplary buildings benefitting the environment by striving for maximum carbon reduction and resource efficiency, renewing rather than re-building
  • Happy, healthy and thriving places to live and/or work, breathing new life into tired buildings to support the livelihood of workers, residents and the local community
  • Development that is truly sustainable, conceived in collaboration with the local stakeholders so that it addresses the needs and aspirations of the entire community and delivers better outcomes for all.

Meaningful consultation is always at the heart of Frogmore’s success and runs throughout these guiding principles. For us, the consultation and planning process is not just a hurdle to overcome. It is an opportunity to engage with local residents, businesses, community organisations and the local authorities so that every development we deliver truly reflects the needs and aspirations of the entire community who will use it.

Since 2021, Frogmore is a signatory to the UN-supported Principles for Responsible Investment (PRI), and commits to PRI’s six Principles for Responsible Investment (Principles), being as follows:

  1. Incorporate ESG issues into investment analysis and decision-making processes;
  2. Be active owners and incorporate ESG issues into ownership policies and practices;
  3. Seek appropriate disclosure on ESG issues by the entities into which investments are made;
  4. Promote acceptance and implementation of the Principles within the investment industry;
  5. Work together to enhance effectiveness in implementing the Principles; and
  6. Report on activities and progress towards implementing the Principles.

Material ESG factors are reviewed at every stage of the investment cycle and each member of staff is expected to consider ESG matters in their work projects and activities. Furthermore, it is important to us that business partners we choose to work with share our approach.

Frogmore’s ESG focus areas

Frogmore has identified ESG issues that are likely to be most significant across our assets, in addition to our obligation to comply with all applicable environmental laws and regulations.

  • Health and Safety: ensuring that all work carried out on our assets adheres to the highest standards of health and safety and that all people working on or visiting any of our sites are kept safe.
  • Energy efficiency: the identification and management of environmental attributes of building materials and enhancement of the energy efficiency of the buildings that we develop and/or refurbish.
  • Site waste management: prevention and reversal of potential adverse impacts arising from development sites and reduction of the amount of waste sent to landfill during construction.
  • Resource management and sourcing: promotion of efficient use of natural resources, the sourcing of materials responsibly – including consideration of human rights risks in the supply chain and requirement of sustainable certifications of materials, where appropriate.
  • Fitness for the future: creation of flexible spaces designed with a long-term view of tenant use. We also design facilities to promote health & wellbeing, clean transport modes and green travel plans.
  • Community impact: active engagement with relevant stakeholders in the local communities to minimise any adverse impact generated by our developments.
  • Business ethics: to embrace responsible business ethics, integrity and transparency across all stages of our investment and development process and compliance with all relevant anticorruption laws and regulations.

Implementation of Responsible Investment

The implementation of Responsible Investment is guided by Frogmore’s proprietary ESG Standards that provide a set of minimum requirements and aspirations for the Frogmore team with regards to ESG practices and outcomes of properties. While the Minimum requirements apply to all properties the Aspirational Standards are to be considered in all cases but pursued only when feasible within the objectives of each business plan.

For each property investment, where relevant, Frogmore will:

  • Carry out appropriate due diligence either prior to acquisition or, if circumstances do not permit, as part of the monthly and quarterly asset management reviews to:
    • identify the ESG risks and opportunities related to it;
    • identify restrictions on the environmental capacity of a development site such as waste management and water resource; and
    • consider the likely ESG requirements for the relevant occupier universe and potential future owners. External service providers are used as necessary.
  • We would not, invest if due diligence uncovered that there was a significant environmental risk, or risk to human health and/or wellbeing that could not be mitigated during the course of Frogmore’s business plan.
  • Prepare an environmental baseline to determine the appropriate measurement for energy efficiency and water usage for each acquisition. Where applicable, our goal is to measure the improvement made or measures taken to reduce future use as a result of our investment.
  • During the asset’s business plan delivery, Frogmore’s Asset Management team will seek to improve the property’s resource efficiency through better design, insulation, incorporation of environmental management systems, use of renewable energy sources (solar panels, wind turbines and other ‘low carbon’ technologies) and/or using local sources of heat and power.
  • Good ESG management will be integrated into the design and construction brief for each asset, together with Frogmore’s statement of intent for the property. This will include considerations around the creation of a ‘well building’ and design flexibility depending on the type of building and on the needs of future tenants.
  • Where applicable, Frogmore will target BREEAM in the business plan for both homes and commercial buildings – an industry standard which incorporates guidelines on materials, energy efficiency, water usage, biodiversity, etc. Frogmore’s aim is to reach BREEAM ‘Very Good’ (at a minimum) for developments, or, for assets where BREEAM is not the appropriate standard we will incorporate elements to improve the building from an environmental and wellness perspective, such as lighting, heating and insulation.
  • Engage with the local community to consider the overall impact of the project. We seek to minimise the negative impact during the construction phase, whilst working together with local stakeholders to create positive outcomes from the development for its community. Examples of such engagement include the support of local economic development programmes, encouragement of employment initiatives and the actively support of groups involved in the improvement and promotion of the locality.

Throughout construction Frogmore will:

  • Review Health & Safety on each project at Board-level during quarterly review meetings which will incorporate an asset-by-asset report on any incidents, including near-misses.
  • Work exclusively with reputable contractors that comply with the relevant Local Authority requirements, that are registered with the Considerate Constructor Scheme and that abide by its Code of Considerate Practice. This Code outlines the Scheme’s expectations and includes areas such as: care about appearance, respect for the community, protection of the environment, secure everyone’s safety and valuing the workforce.
  • The Local Authority will also often require a Construction Traffic Management Plan and a Construction Environment Management Plan. These set out proposed principles and requirements including waste, dust, vibration and noise-level management to minimise the impact of the construction process on neighbouring occupiers, the environment and how these will be managed and mitigated. Frogmore will ensure that legal contracts contain ESG issues and will monitor contractors’ compliance with these requirements during the term of the agreement
  • Complaint management – Frogmore has a requirement that its managing agents and/or contractors report on complaints received about each asset. These are reviewed by the relevant team as soon as possible and an aggregated report forms part of the monthly and quarterly Asset Management Review meetings.
  • While these reports are not always escalated to the Board for its quarterly review meeting, any significant complaints or issues will be brought immediately to the attention of the Investment Committee and will be raised by our Senior Development Manager as part of their quarterly Board-level report.

Throughout Frogmore’s ownership of tenanted buildings, we will:

  • Work with managing agents who embrace efficiency improvements by the implementation of Environmental Management Systems and/or Plans at Frogmore’s assets which will facilitate the efficient management of energy and water use.
  • Encourage and support managing agents and tenants to maximise resource efficiency and minimise waste in their building use by facilitating monitoring and sharing best practices. Frogmore will require tenants to consider environmental impacts and efficiency measures prior to granting licences to alter and will encourage the attainment of sustainable refurbishment standards.
  • Be a responsible landlord by considering, wherever possible, the wider community and social impact of the tenant mix.

ESG Reporting to Investors

  • Frogmore will communicate ESG-related performance information to its investors on an annual basis.
  • Frogmore will also report annually to the PRI Assessment.

ESG Governance at Frogmore

  • During the Quarterly Review and Investment Committee meetings, the Asset Management Team will report on and consider all material aspects described in ‘Frogmore’s ESG Focus Areas’. The Director of Asset Management will also monitor these aspects with their team at the monthly Asset Management meetings.
  • The Director of Asset Management is responsible for the implementation of this policy which will be reviewed on an annual basis by Frogmore’s Chief Executive and updated as necessary.
  • Frogmore is committed to ensuring that this policy is effectively implemented and will provide sufficient resource and training to its team members to enable them to comply with this policy.

ESG in performance reviews and remuneration

Each member of staff undergoes an annual review of their performance against stated objectives with their immediate manager. When assessing individual performance and determining the individual remuneration Frogmore takes account of financial as well as non-financial criteria. The non-financial criteria are a combination of effective risk management and compliance with Frogmore’s policies and procedures, including this Responsible Investment Policy and related procedures.

This policy statement was approved by the Investment Committee on 16 March 2021.