November 2024

Environmental, Social, and
Governance (“ESG”) Policy

Introduction 

Accelerate Infrastructure Opportunities, LLC (“Accelerate” or the “Company”) acquires, owns, and manages real property interests in, under, and related to critical infrastructure assets that generate long-term, sustainable cash flow, such as leases and land under cellular infrastructure, data centers, billboards, and renewable assets, including wind, solar, storage, and EV charging projects. Accelerate focuses on developing mutually beneficial, long-term relationships with property owners, tenants, developers, operators, and brokers. Its collaborative approach and creative capital solutions provides value to its partners, while also delivering differentiated risk-adjusted returns for investors. 

The Company has undertaken an ESG materiality assessment to identify the issues material to its operations and long-term resilience, which was endorsed by the Board of Directors. 

This ESG Policy details the Company’s commitments in relation to the material ESG matters as derived from the materiality assessment. 

Governance 

This policy applies to Accelerate in its entirety and will be updated periodically by management to reflect regulatory, industry, market, and other developments. 

Accelerate recognises the impacts its activities have on the environment, natural resources, and the community and is committed to integrate ESG considerations in all aspects of its business. This policy applies to the Company and its contractors. 

Accelerate shall endeavor to ensure its suppliers adhere to the principles of this policy and observe and comply with all applicable environmental, human rights, health, safety, labour and conduct Laws of the jurisdictions in which they do business. 

The Board of Directors has ultimate oversight for the implementation of the ESG Policy, which will review and approve annually, at a minimum. Importantly, the Board of Directors will monitor and have oversight over Accelerate’s efforts and commitment to achieve Net Zero by 2050 at the latest. 

Materiality statement 

ESG matters material to Accelerate include: 

– Climate change risk and resilience: assessment, identification and management of the likelihoods, consequences and impacts of climate change and adaptation and mitigation efforts, covering both climate transition risk (policy and legal, technology, market and reputation risk driven by the transition to a low carbon economy) and climate physical risk (acute and chronic risk driven by the physical impact of climate change) 

– Air pollution, greenhouse gas emissions and Net Zero: the release of particles and gases released into the atmosphere that may adversely affect living organisms, contributing to climate change or exacerbating its effects, coupled with (a) the release of greenhouse gas emissions, and (b) the identification, assessment and implementation of initiatives aimed at progressively reducing them, contributing to the global achievement of Net Zero targets 

– Hazardous substances: awareness, recognition, monitoring, management (including remediation) of any substance of chemical which is a health hazard or physical hazard, particularly with respect to property that the Accelerate acquires in fee 

– Natural capital: awareness, recognition, monitoring and management of the company’s dependency and impact on the world’s natural resources, including reduction of pollution, efficient resources sourcing (including related to energy use and consumption), management and consumption, waste management and protection of land, soil, air, water and all living organisms 

– Health, safety and wellbeing: policies, processes, training, recording, reporting and investigation of incidents concerning employees, contractors and users making up the occupational health, safety and wellbeing management systems 

– Fair working conditions: fair pay, equal pay for work of equal value, freedom of association, representation, training, development and employee engagement, monitoring of labour standards and working conditions, particularly as the Company’s footprint expands. 

– Community Impact and Engagement: ensuring the Company serves its community, and positively contributes its time and resources to generating solutions to common problems 

– Diversity, Equity and inclusion: ensuring equitable, fair and unbiased access to opportunities for all, at all levels, and a workplace free from harassment and discrimination, in alignment with Principle 6 of the UN Global Compact 

– Employee and Stakeholder engagement: interactions with employees and stakeholders can have a material impact on the Company’s performance, including but not limited to supporting the growth and development of employees 

– Board composition, skills and diversity: the composition of the Board, the presence of non-executive and/or independent directors, shareholder representatives, and management representatives, the independence of the Board Chair, cognitive, gender, age, race and background diversity and the regular assessment of the Board’s activities and composition 

– Oversight of sustainability and reporting: the integration of sustainability into governance frameworks and the degree of Board involvement coupled with transparent reporting of sustainability information and verifiable data. 

– Fraud, Bribery and Corruption: the adoption and implementation of policies and processes aimed at ensuring alignment with the highest ethical standards, including anti-bribery, anti-fraud and anti-corruption provisions in alignment with Principle 10 of the UN Global Compact 

– Cyber security and data protection and privacy: the policies, processes, monitoring and reporting of the protection of the internet connected systems and of data 

– Responsible procurement and supply chain management: ensuring the procurement strategy for the Company upholds sustainability, human rights, and anti-corruption / bribery standards, including, inter alia, no engagement in and condonement of any forms of forced and compulsory labor, as per principle 4 of the UN Global Compact, no engagement in and condonement of child labor, as per principle 5 of the UN Global Compact

The table below summarises the ESG risks material to Accelerate and addressed by this policy.  

Environmental	Materiality
Air pollution	Medium relevance
Biodiversity and habitat	Low relevance
Energy consumption	Medium relevance
Greenhouse gas emissions	Medium relevance
Hazardous substances	Low relevance
Material sourcing and resource efficiency	Medium relevance
Net zero	Medium relevance
Physical Risk	High relevance
Waste	Medium relevance

Social	Materiality
Community development	Medium relevance
Customer satisfaction	Low relevance
Diversity, Equity and Inclusion	Medium relevance
Employee engagement	Medium relevance
Freedom of association	Low relevance
Health and Safety: Community	Low relevance
Health and Safety (H&S): Employees	High relevance
Health and Safety (H&S): Supply Chain	Medium relevance
Labour standards and working conditions	Low relevance
Local employment	Medium relevance
Stakeholder Relations	Medium relevance

Governance	Materiality
Board ESG Oversight	Medium relevance
Bribery and Corruption	Low relevance
Conflicts of Interest	Medium relevance
Cybersecurity	Medium relevance
Data Protection & Privacy	Medium relevance
Delegating Authority	Medium relevance
Executive Compensation	Medium relevance
Fraud, Bribery, and Corruption	Medium relevance
Lobbying Activities	Medium relevance
Political Contributions	Medium relevance
Shareholder Rights	Medium relevance
Whistleblower Protection	Medium relevance

ESG Policy

 Accelerate will responsibly deliver investment-related real estate services in the United States. In doing so, the Company adopts the following commitments and objectives, at a minimum: 

– Comply with all environmental laws of the jurisdictions in which it does business. The Company’s targets to have zero violations of environmental laws at its office locations in Plano, Texas, New York, New York, Los Angeles, California, and Oklahoma City, Oklahoma; 

– Develop and maintain robust H&S policies and processes to ensure the safety of all employees, contractors, users and community members, fostering a strong safety culture at all levels, including in the selection of suppliers with expectation and target of zero work-related fatalities, accidents, and injuries, which shall be tracked on annual basis; 

– Assess, monitor and report its impacts on the environment, including biodiversity, energy consumption and greenhouse gas emissions, and waste generation. Implement and track recycling programs to reduce waste, and progressively lower overall environmental footprint in the transition to net zero; 

– Monitor and assess its resilience to climate-related risks, including transition and physical risks, and identify initiatives to contribute to the achievement of global Net Zero targets by 2050, at the latest; 

– Create and foster a diverse, equitable and inclusive working environment, where employees are valued and their perspective accounted for via employee engagement, promoting a working environment free from harassment and discrimination, including via offering equal remuneration for work of equal value; 

– Create and maintain stakeholder engagement policy updated at least annually; 

– Conduct employee satisfaction surveys at least annually targeting an eNPS score of at least 80% and conduct employee reviews at least semi-annually; 

– Conduct an annual compliance trainings on topics determined by the Human Resources and Legal Departments; 

– Protect human rights, including freedom of association, ensuring labour standards and working conditions comply with local regulations and international conventions and best practices; 

– Ensure no engagement in and condonement of any forms of forced and compulsory labor and child labor; 

– Endeavour to make a positive contribution to local employment and community development; 

– Uphold to the highest standards of corporate governance and business ethics, including on anti-bribery, anti-fraud and anti-corruption, protecting shareholder rights and ensuring transparency; 

– Comply with laws, regulations and guidelines and to perform regular conformity assessments to ensure compliance with applicable requirements; 

– Identify and manage conflicts of interest, notifying the Board as appropriate; 

– Proactively monitor and manage cybersecurity, with due care given to data protection and privacy, especially with reference to personal information; 

– Provide the Board with transparent and reliable ESG information on a quarterly basis to support its oversight on such matters; 

– Adhere to its contractual commitments to shareholders, targeting to deliver all reports due to shareholders timely as set forth in such contractual commitments; 

– Maintain and encourage the disclosure of wrongdoing or illicit acts and protect the integrity and anonymity of the whistleblowing process; and 

– Report cybersecurity breaches involving personal information or significant environmental concerns to the relevant regulatory authorities in compliance with applicable laws.