K-Fastigheter

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K-Fast Holding AB

Green Bond Second Opinion

November 19, 2021

K-Fast Holding AB (publ) (“K-Fastigheter”) is a Swedish project development, construction and property management company focused on rental housing properties. K-Fastigheter was founded in 2010 and the group holds a strong position in the Öresund region and in selected towns and cities in southern and western Sweden. In 2020, K-Fastigheter established operations in Denmark and in the Swedish region Mälardalen. K-Fastigheter acquired Finja Prefab AB in December 2020. Finja Prefab, today operating under the brand K- Prefab, is a nationwide actor within prefabricated concrete building components.

The Green bond framework of K-Fastigheter covers the categories Green and energy efficient buildings and Renewable energy. The majority of the proceeds will, according to the issuer, go to new financing of Green and energy efficient buildings. The eligibility criteria for green bond proceeds for green buildings are energy efficiency related, although K-Fastigheter also has an ambition that new own produced buildings should fulfill the building criteria of Miljöbyggnad Silver.

This category receives a Light green shading due to the relatively modest energy requirements compared to current building regulations. The issuer informs us that only buildings completed in 2021 or afterwards are currently planned included under the framework, but aquisition of older buildings are not ruled out. The considerations of life cycle emissions of building material for new buildings are not quantified in a way that shows whether they substantially reduce emissions.

Renewable energy is solar and wind power.

The governance score of K-Fastigheter is good. While the company has targets when it comes to sourcing of electricity, there are no quantitative targets for overall energy use or greenhouse gas emissions. K-Fastigheter does not report scope 2 or 3 emissions. K-Fastigheter’s Code of conduct for suppliers (in draft form) is strong on both social and environmental risk factors. The selection process is good.

Management of proceeds is in accordance with the Green Bond Principles.

Reporting is covering key allocation and performance indicators. Reporting on climate risks do not follow the TCFD guidelines.

Based on the overall assessment of the eligibility criteria in this framework, governance and transparency considerations, and the prioritized use of proceeds, the framework receives a CICERO Light Green shading and a governance score of Good. In order to achieve a darker green shading, the green bond framework would need stronger eligibility criteria in the Green and energy efficient buildings category and better support from the company’s policies, targets and strategies, in particular with respect to climate targets and life cycle impacts of materials.

SHADES OF GREEN Based on our review, we rate the K-Fastigheter’s green bond framework CICERO Light Green.

Included in the overall shading is an assessment of the governance structure of the green bond framework.

CICERO Shades of Green finds the governance procedures in K-

Fastigheter’s framework to be Good.

GREEN BOND PRINCIPLES Based on this review, this Framework is found in alignment with the principles.

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This note provides CICERO Shades of Green’s (CICERO Green) second opinion of the client’s framework dated November 2021. This second opinion remains relevant to all green bonds and/or loans issued under this framework for the duration of three years from publication of this second opinion, as long as the framework remains unchanged. Any amendments or updates to the framework require a revised second opinion. CICERO Green encourages the client to make this second opinion publicly available. If any part of the second opinion is quoted, the full report must be made available.

The second opinion is based on a review of the framework and documentation of the client’s policies and processes, as well as information gathered during meetings, teleconferences and email correspondence.

Expressing concerns with ‘Shades of Green’

CICERO Green second opinions are graded dark green, medium green or light green, reflecting a broad, qualitative review of the climate and environmental risks and ambitions. The shading methodology aims to provide transparency to investors that seek to understand and act upon potential exposure to climate risks and impacts.

Investments in all shades of green projects are necessary in order to successfully implement the ambition of the Paris agreement. The shades are intended to communicate the following:

Sound governance and transparency processes facilitate delivery of the client’s climate and environmental ambitions laid out in the framework. Hence, key governance aspects that can influence the implementation of the green bond are carefully considered and reflected in the overall shading. CICERO Green considers four factors in its review of the client’s governance processes: 1) the policies and goals of relevance to the green bond framework;

2) the selection process used to identify and approve eligible projects under the framework, 3) the management of proceeds and 4) the reporting on the projects to investors. Based on these factors, we assign an overall governance grade: Fair, Good or Excellent. Please note this is not a substitute for a full evaluation of the governance of the issuing institution, and does not cover, e.g., corruption.

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2 Brief description of K-Fastigheter’s green bond framework and related policies

K-Fast Holding AB (publ) (“K-Fastigheter”) is a Swedish project development, construction and property management company focused on rental housing properties. K-Fastigheter was founded in 2010 and holds a strong position in the Öresund region and in selected towns and cities in southern and western Sweden. In 2020, K- Fastigheter established operations in Denmark and in the Swedish region Mälardalen. K-Fastigheter’s business concept is to own and manage homes with an unlimited time frame.

In 2020, K-Fastigheter had 2,237 homes under management, 1,311 homes under construction and 3,880 homes under project development. The property value was 5,067 billion SEK with a management result of 75.3 million SEK. K-Fastigheter had 76 employees at the end of 2020. K-Fastigheter acquired Finja Prefab AB in December 2020. Finja Prefab, today operating under the brand K-Prefab, is a nationwide actor within prefabricated concrete elements.

Environmental Strategies and Policies

K-Fastigheter’s operations are mainly governed by its codes of conduct, which is based on the ten principles in the UN’s Global Compact, the OECD’s guidelines for multinational companies and the UN’s guiding principles for companies and human rights, the Construction Companies Code of Conduct and other regulations that companies within the K-Fast Group follow through membership and other commitments. The Code of conduct for suppliers sets requirement for environmental management, including use of materials, while separate documents govern procurement practices, human resources management and gender equality issues.

Key sustainability issues are, according to K-Fastigheter: reduced consumption of water, reduced electricity use;

use of long-term climate-smart construction materials; minimizing materials use; and reduced CO2 footprint. To meet these challenges K-Fastigheter has implemented or decided to implement the following actions: 100% of purchased electricity has been fossil-free since 2019, solar cells are installed on all concept buildings that started construction from spring 2021 except for low rise buildings, solar cells will be installed at all of K-Prefab’s production facilities in 2022, the car policy only approves electric and hybrid cars, and in all new production, low- flush nozzles are installed. K-Fastigheter has no use of fossil fuels.

Climate resilience issues are according to K-Fastigheter fully covered by the public planning requirements.

Sustainability concerns are addressed in their annual reports, but TCFD guidelines are not followed.

Among the sustainability targets put forward by K-Fastigheter for 2023 we note:

- Electricity consumption in K-Fastigheter’s offices and production plants shall be sourced from own photovoltaic cells/fossil-free energy (current status is that solar cells are installed at K-Prefab’s production facility in Hässleholm and covers 50% of the need. In addition there are solar cells at the head office in Hässleholm which cover 100% of the need from the office plus the wall factory in Hässleholm).

- All new-build lateral low-rise and apartment block buildings shall source as much electricity from photovoltaic cells as possible. The rest will be fossil free electricity.

- Water consumption for the total property holding shall be reduced to match the average for the group’s proprietary concept buildings.

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- Compared to 2020, K-Fastigheter shall double its production of renewable energy and use the electricity produced to operate and heat the company’s vehicles, properties and production plants, and sell surplus energy

- The ten largest suppliers of construction materials shall have been reviewed from a sustainability perspective under K-Fastigheter’s updated Code of conduct.

K-Fastigheter’s proprietary concept buildings are constructed with the ambition of meeting requirements corresponding to those set by Miljöbyggnad Silver in terms of energy, indoor environment and chemicals. One advantage of prefabricated manufacturing methods is more optimized products requiring smaller quantities of materials, helping reduce the number of shipments of building materials, while making it easier to handle the waste that always arises during production.

On 1 August 2020, new regulations were introduced governing the management of construction and demolition waste in Sweden. K-Fastigheter satisfies the requirements for removing certain types of waste and storing this waste separately from certain other kinds of waste and from general waste. Generally, K-Fastigheter has mostly

“green-field” projects without demolition. When demolition is required, there is a demolition plan where all recyclable materials are recycled, according to the issuer.

K-Fastigheter reports emissions data for 2020 for Scope 1 (data from the company’s vehicles) based on standardized calculations of actual consumption. In 2020, the consumption equalled 111 metric tons of CO2. The portfolio energy use per square meter in 2020 was 112 kWh/m², mainly district heating, down from 138 kWh/m² in 2019. According to K-Fastigheter, its own constructed properties have on average an energy use of 54 kWh/m² while aquiried properties has an energy use of 148 kWh/m².

Use of proceeds

An amount equal to the net proceeds of the green bonds will finance or refinance, in whole or in part, investments undertaken by K-Fastigheter or its subsidiaries (“Green Projects”), in each case as determined by K-Fastigheter in accordance with the green project categories defined in table 1. An initial estimate is that 2/3 will be for new projects, while 1/3 will be refinancing. The categories included in the framework are Green and energy efficient buildings and Renewable energy. Initially, approximately 95% of the proceeds will be for Green and energy efficient buildings. Green projects will form a portfolio of assets eligible for financing and refinancing by green bonds. New financing is defined as green projects financed after the bond has been issued, and refinancing is defined as green projects financed prior to the bond issuance. The distribution between new financing and refinancing will be reported on in K-Fastigheter annual green bond report.

Green bond net proceeds will not be allocated to projects for which the purpose is fossil energy production, nuclear energy generation, weapons and defense, potentially environmentally harmful resource extraction (such as rare- earth elements or fossil fuels), gambling or tobacco. Buildings with fossil fuel heating are also excluded, according to the issuer.

Selection

The selection process is a key governance factor to consider in CICERO Green’s assessment. CICERO Green typically looks at how climate and environmental considerations are considered when evaluating whether projects can qualify for green finance funding. The broader the project categories, the more importance CICERO Green places on the governance process.

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Green projects shall comply with the eligibility criteria defined in table 1 and will include an active dialogue with potential stakeholders in the local area if necessary. The process of evaluating and selecting eligible green projects as well as the allocation of green bond proceeds to eligible green projects comprise the following steps:

i. Representatives from K-Fastigheter’s different business segments, supported from time to time by external sustainability experts, evaluate potential green projects, their compliance with the green project categories, and their environmental benefits.

ii. A list of the potential green projects is presented to K-Fastigheter’s Green Bond Committee (“GBC”).

The GBC is solely responsible for the decision to acknowledge the project as green, in line with the green project criteria. Green projects will be marked as green in a dedicated “Green Register”. A decision to allocate net proceeds will require a consensus decision by the GBC. The decisions made by the GBC will be documented and filed.

The GBC is chaired by the Chief Financial Officer and includes the following members: Chief Executive Officer, Chief Financial Officer, Head of Communications/IR, Head of Construction, and Head of Property Management.

External evaluation will be called upon if needed. The GBC will convene every 6 months or when otherwise considered necessary. The GBC holds the right to exclude any green project already funded by green bond net proceeds. If a green project is sold, or for other reasons loses its eligibility, funds will then follow the procedure under Management of Proceeds until reallocated to other eligible green projects.

Management of proceeds

CICERO Green finds the management of proceeds of K-Fastigheter to be in accordance with the Green Bond Principles.

K-Fastigheter will use a green register to track the allocation of net proceeds from green bonds to individual green projects. The management of proceeds will be reviewed by an independent external party appointed by K- Fastigheter.

Unallocated green bond net proceeds may temporarily be placed in the liquidity reserve and managed accordingly by K-Fastigheter. The portfolio balance of unallocated proceeds will be disclosed. Temporary holdings will not be placed in entities with a business plan focused on fossil energy generation, nuclear energy generation, research and/or development within weapons and defence, environmentally negative resource extraction, gambling or tobacco.

Reporting

Transparency, reporting, and verification of impacts are key to enable investors to follow the implementation of green finance programs. Procedures for reporting and disclosure of green finance investments are also vital to build confidence that green finance is contributing towards a sustainable and climate-friendly future, both among investors and in society.

To enable the monitoring of performance and provide insight into prioritised areas, K-Fastigheter will annually and until maturity of the green bonds issued, provide investors with a report (“Green Bond Report”) that describes the allocation of proceeds and the environmental impact of the green projects. The CFO is responsible for the reporting and a first report is expected in April 2022. The report will be made available on K-Fastigheter’s website, www.k-fastigheter.com, together with the green bond framework.

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Allocation reporting will be on a project-by-project basis and will include a summary of green bond developments;

the outstanding amount of green bonds issued, presented per type of green bond instrument; the balance of the green projects in the green register (including any temporary investments and green bond repayments) and the available headroom in the value of the green projects (if any); the total proportion of green bond net proceeds used for new financeing and refinance of green projects, respectively; and the total aggregated proportion of green bond net proceeds used per green project category and which environmental objective is targeted. All project financed will be listed and the green bond share of financing will be reported. The reporting will not be linked to individual bonds.

The impact reporting aims to disclose the environmental impact of the green projects financed under K- Fastigheter’s green bond framework, based on K-Fastigheter’s financing share of each project. As K-Fastigheter can finance a large number of smaller green projects in the same project category, impact reporting will, to some extent, be aggregated. The impact assessment is provided with the reservation that not all related data can be covered and that calculations therefore will be on a best effort basis.

The impact assessment will, if applicable, be based on the following metrics:

• For Green and energy efficient buildings: Annual energy use avoided compared to the relevant national building regulation (kWh/m²) and annual GHG emissions avoided (tonnes of CO2e emissions).

• Renewable energy: Installed renewable energy capacity (kW), annual renewable energy generation (kWh), and annual GHG emissions avoided (tonnes of CO2e emissions)

The grid factor used will be aligned with the Nordic Public Sector Issuers Position Paper¹, i.e., 315 g CO2e/kWh.

An independent external party, appointed by K-Fastigheter will on an annual basis provide a review, confirming that an amount equal to the green bond net proceeds has been allocated to green projects. The impact reporting will not be independently reviewed or verified.

1 https://www.kuntarahoitus.fi/app/uploads/sites/2/2020/02/NPSI_Position_paper_2020_final.pdf

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3 Assessment of K-Fastigheter’s green bond framework and policies

The framework and procedures for K-Fastigheter’s green bond investments are assessed and their strengths and weaknesses are discussed in this section. The strengths of an investment framework with respect to environmental impact are areas where it clearly supports low-carbon projects; weaknesses are typically areas that are unclear or too general. Pitfalls are also raised in this section to note areas where K-Fastigheter should be aware of potential macro-level impacts of investment projects.

Overall shading

Based on the project category shadings detailed below, and consideration of environmental ambitions and governance structure reflected in K-Fastigheter’s green bond framework, we rate the framework CICERO Light Green.

Eligible projects under the K-Fastigheter’s green bond framework

At the basic level, the selection of eligible project categories is the primary mechanism to ensure that projects deliver environmental benefits. Through selection of project categories with clear environmental benefits, green bonds aim to provide investors with certainty that their investments deliver environmental returns as well as financial returns. The Green Bonds Principles (GBP) state that the “overall environmental profile” of a project should be assessed and that the selection process should be “well defined”.

Category Eligible project types Green Shading and some concerns Green and

energy efficient buildings

• Construction of buildings² designed to operate, once completed, at an energy use 10% below the national building regulation³. In new constructions, climate risks and life- cycle emission effects are considered.

• Existing buildings with an energy use 10%

below the national building regulation³.

Light Green

ü This category receives a Light green shading due to the relatively modest energy requirements compared to current building regulations. The considerations of life cycle emissions of building material for new buildings are not quantified in a way that shows whether they substantially reduce emissions.

ü The green project category is intended to reflect the technical screening criteria in the EU Taxonomy regulation Delegated act annex 1 (June 2021)⁴. K-Fastigheter acknowledges the accompanying do-no- significant-harm criteria related to:

circular economy elements such as re-

2 May cover land held for development and its development costs, and development costs related to buildings under construction that will, once completed, reach the eligibility criteria for the category.

3Prevailing at the time the building permit was issued, i.e., BBR28 or BBR29.

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use as well as recycling or material recovery of construction waste, pollution minimization, biodiversity protection and in case of new construction, no

construction on arable land, forest land or greenfield land of high biodiversity.

CICERO Shades of Green has not assessed the taxonomy alignment.

ü The issuer informs us that only buildings completed in 2021 or afterwards are currently planned included in this category, but acquisition of older buildings at a later stage is not excluded.

Renewable energy

The financing or refinancing of investment in products that generate renewable energy, as well as associated infrastructure.

• Solar energy technologies, such as Photovoltaic systems (PV).

• Onshore wind energy generation facilities.

Dark Green

ü Renewable energy is part of a Dark Green Solution and is key to a low- carbon transition.

ü To limit emissions from its renewable energy projects, we encourage K- Fastigheter to do life cycle analysis.

Table 1. Eligible project categories

Background

The real estate sector is the single largest energy consuming sector in the EU, responsible for about 40% of total energy consumption and 36% of total carbon emissions. Investing in green and energy efficient buildings thus play a key role in the energy transition.

As member of the EU, Sweden is subject to the EU’s climate targets of reducing collective EU greenhouse gas emissions by 40% by 2030 compared to 1990 levels, increasing the share of renewable energy to 32% and improving energy efficiency by at least 32.5%⁵. The European Green Deal aims for carbon neutrality in 2050.⁶

The construction and real estate sector have a major impact on our common environment. According to the National Board of Housing, Building and Planning’s environmental indicators, it accounts for 32% of Sweden’s energy use, 31% of waste and 19% of domestic greenhouse gas emissions. IEA reports that the efficiency of building envelopes needs to improve by 30% by 2025 to keep pace with increased building size and energy demand – in addition to improvements in lighting and appliances and increased renewable heat sources.⁷ Additionally, in the Nordic context approximately half of life-cycle emissions from buildings stem from materials/construction.

The other half stems from energy use, which becomes less important over time with the increasing adoption of off-grid solutions such as geothermal and solar. All of these factors should therefore be considered in the project selection process.

5 https://ec.europa.eu/clima/policies/strategies/2030_en

6 https://ec.europa.eu/info/strategy/priorities-2019-2024/european-green-deal_en

7 https://www.iea.org/reports/building-envelopes

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Voluntary environmental certifications such as Miljöbyggnad and Green Building or equivalents measure or estimate the environmental footprint of buildings and raise awareness of environmental issues. These points-based certifications, however, fall short of guaranteeing a low-climate impact building, as they may not ensure compliance with all relevant factors e.g., access to public transport and climate resilience. Many of these factors are covered under the World Green Building Council’s recommendations for best practices for developing green buildings.⁸ CICERO Shades of Green assesses all of these factors when evaluating the climate impact of buildings.

The Exponential Roadmap⁹ lays out a trajectory for reducing emissions by 50% by 2030 and requires that emissions reductions strategies within the buildings sector be rapidly scaled up. The roadmap advocates for standardised strategies that are globally scalable within areas such as new procurement practices for construction and renovation that require dramatically improved energy and carbon emission standards, developing new low- carbon business models for sharing space and smart buildings to achieve economies of scale, and allocating green finance funding for sustainable retrofitting and construction.

Governance Assessment

Four aspects are studied when assessing the K-Fastigheter’s governance procedures: 1) the policies and goals of relevance to the green bond framework; 2) the selection process used to identify eligible projects under the framework; 3) the management of proceeds; and 4) the reporting on the projects to investors. Based on these aspects, an overall grading is given on governance strength falling into one of three classes: Fair, Good or Excellent. Please note this is not a substitute for a full evaluation of the governance of the issuing institution, and does not cover, e.g., corruption.

While the company has targets when it comes to sourcing of electricity, there are no quantitative targets for overall energy use or greenhouse gas emissions. The board of K-Fastigheter holds ultimate responsibility for K- Fastigheter’s sustainability agenda and the continuous sustainability work. K-Fastigheter’s CEO delegates operational responsibility to each business area manager. For development and support, the company has established a steering committee consisting of K-Fastigheter’s CEO, CFO, HR Director and IR and Communication Manager.

K-Fastigheter’s Code of conduct for suppliers (in draft form) is strong on both social and environmental risk factors. K-Fastigheter has a whistleblower function to ensure the correct application of the Group’s Code of Conduct. To ensure anonymity and correct processing of the information, the function is administrated by an external party.

Climate and environmental risk related to K-Fastigheter’s operations are estimated to mainly include the physical environment which affects people and buildings, and production and prices of natural resources in the form of materials and energy. K-Fastigheter do not report scope 2 or 3 greenhouse gas emissions and.

8 https://www.worldgbc.org/how-can-we-make-our-buildings-green

9 https://exponentialroadmap.org/wp-

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The selection process is good. Management of proceeds is in accordance with the Green Bond Principles. Reporting is covering key allocation and performance indicators. Reporting on climate risks does not follow the TCFD guidelines.

The overall assessment of K-Fastigheter’s governance structure and processes gives it a rating of Good.

Strengths

The use of prefabricated modules for houses is a step towards less wasteful construction practice. The energy use in the existing portfolio of buildings is reasonably good and proves that K-Fastigheter realistically can fulfill the eligibility criteria for the category Green and energy efficient buildings. The exclusion of fossil fuel technologies is a strength of the framework.

Weaknesses

We find no material weaknesses in K-Fastigheter’s green bond framework.

Pitfalls

In a low carbon 2050 perspective, the energy performance of buildings is expected to be improved, with passive house technology becoming mainstream and the energy performance of existing buildings greatly improved through refurbishments. According to IEA, efficiency of building envelopes needs to improve by 30% by 2025 to keep pace with increased building size and energy demand – in addition to improvements in lighting and appliances and increased renewable heat sources. The criteria for eligible projects under the Green buildings category are good, but do not yet delivering the solutions needed in a low carbon 2050 perspective (passive house technology and similar). The issuer is taking a step in this direction with the energy efficiency criteria. In order to achieve a darker green shading, the green finance framework would need a stronger energy efficiency criteria in eligible green building projects.

Lack of quantitative target for greenhouse gas emissions at the company level in both short-term and long-term (at least scope 1 and 2), is currently a weakness in governance. This will, however, be remedied in the near future (next year). Lack of time series reporting of emissions makes it difficult to assess progress towards its long-term green development. There is also a lack of scenario analysis whether or not formally in alignment with the TCFD recommendations.

The grid factor used will be aligned with the Nordic Public Sector Issuers Position Paper. This is usually higher than the local de facto grid factor and investors should be aware of this when K-Fastigheter starts to report on grid based greenhouse gas emissions.

To the extent that the buildings rely on district heating, there is an inherent probability that some fossil fuel fractions (e.g., plastics) will be involved, although Swedish district heat providers generally are good at tracking and reducing fossil fractions. The issuer informs us that they have ongoing dialogues with local energy companies and that all of them have goals to decrease their greenhouse gas emissions and become fossil free. The investors should be aware that the share of fossil fuels in district heating are significantly higher in countries like Denmark.

Rebound effects represent a category of macro impacts. For example, improved energy efficiency of a dwelling and lower energy costs may induce tenants to increase the indoor temperature, partly offsetting the initial anticipated energy and carbon dioxide savings. While one could argue that these issues should rather be tackled

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through carbon pricing, it is important that issuers are aware of these potential rebound effects and seek to minimize them. In some cases, issuers may be able to mitigate this effect: e.g., building owners or developers could encourage tenants to use clean energy.

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Appendix 1:

Referenced Documents List

Document Number

Document Name Description

1 K-Fastigheter Green Bond Framework 20211020 K-Fastigheter’s Green bond framework dated October 2021

2 K-Fast-Holding-AB-Annual-Report-2020_web K-Fastigheter’s Annual report 2020 (including sustainability report)

3 K-Fastigheter-Carnegie-Real-Estate-Seminar-2021 A presentation of K-Fastigheter

4 K-Fastigheter - Uppförandekod 2021_okt K-Fastigheter’s Code of Conduct (draft)

5 K-Fastigheter - Uppförandekod 2021_leverantörer_okt

K-Fastigheter’s Code of Conduct for suppliers (draft)

6 Jämställdhetsplan 191114 K-Fastigheter’s gender equality plan

7 Inköps och upphandlingspolicy 191114 K-Fastigheter’s Procurment policy

8 HR-policy 201020 K-Fastigheter’s human resources policy

9 Energibalansberäkningar An Excel sheet with energy data per building in the current portfolio

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Appendix 2:

About CICERO Shades of Green

CICERO Green is a subsidiary of the climate research institute CICERO. CICERO is Norway’s foremost institute for interdisciplinary climate research. We deliver new insight that helps solve the climate challenge and strengthen international cooperation. CICERO has garnered attention for its work on the effects of manmade emissions on the climate and has played an active role in the UN’s IPCC since 1995. CICERO staff provide quality control and methodological development for CICERO Green.

CICERO Green provides second opinions on institutions’ frameworks and guidance for assessing and selecting eligible projects for green bond investments. CICERO Green is internationally recognized as a leading provider of independent reviews of green bonds, since the market’s inception in 2008. CICERO Green is independent of the entity issuing the bond, its directors, senior management and advisers, and is remunerated in a way that prevents any conflicts of interests arising as a result of the fee structure. CICERO Green operates independently from the financial sector and other stakeholders to preserve the unbiased nature and high quality of second opinions.

We work with both international and domestic issuers, drawing on the global expertise of the Expert Network on Second Opinions (ENSO). Led by CICERO Green, ENSO contributes expertise to the second opinions, and is comprised of a network of trusted, independent research institutions and reputable experts on climate change and other environmental issues, including the Basque Center for Climate Change (BC3), the Stockholm Environment Institute, the Institute of Energy, Environment and Economy at Tsinghua University, the International Institute for Sustainable Development (IISD) and the School for Environment and Sustainability (SEAS) at the University of Michigan.