CleanCapital ESG Policy

CleanCapital recognizes that managing sustainability, or environmental, social, and governance (ESG) issues, is fundamental to the success of our business and creates long-term value for our stakeholders. It helps manage risks, protect value, create a better work environment, and identify opportunities to better manage and operate our business, while enhancing long-term returns for our stakeholders.

We aspire to be an industry leader and integrate leading sustainability measures throughout our business.

Date of latest revision: December 30, 2022


As we strive to deliver our sustainability vision, we commit to:


  1. Minimize impacts to habitat, biodiversity, and natural resources in the areas where we operate.
  2. Contribute to decarbonization via production of renewable energy and reduction of GHG emissions.
  3. Source, manage, and dispose of materials and equipment responsibly and efficiently.


  1. Prioritize health & safety in all operations and minimize the risk of incidents.
  2. Invest in key stakeholder relationships including customers, investors, and community members.
  3. Foster an inclusive and rewarding place to work.


  1. Prioritize ESG via board-level reporting and oversight, executive compensation, and corporate strategy.
  2. Identify, assess, and develop strategies to mitigate ESG-related risks.
  3. Maintain and inform employees and other stakeholders of ESG-related policies and guidelines.


We are dedicated to embedding sustainability across our business units, including construction, asset management, human resources, and the executive team. To meet our commitments, we undertake the activities below:

Construction / Procurement

  1. Monitor and set targets for habitat and biodiversity impacts via the GRESB assessment.
  2. Work with construction contractors to minimize habitat loss, support biodiversity and habitat enhancement, and achieve responsible and efficient sourcing and use of materials in construction.
  3. Take measures in brownfield development to ensure control and containment of contaminated land underlying project sites during and after development.
  4. Require suppliers to comply with all key US federal and international environmental, social, and governance-related laws and regulations.
  5. Maintain practices to minimize the risk of health & safety incidents among employees, contractors, and suppliers, and monitor and set targets for health & safety incidents via the GRESB assessment.
  6. Where feasible, pursue local hiring for construction, maintenance, and other project activities.

Asset Management

  1. Monitor and set targets for renewable energy generation, GHG emissions avoided, and water withdrawals in operations via the GRESB assessment.
  2. Maximize generation of renewable energy via active management and optimization of assets to contribute to local and national decarbonization efforts.
  3. Minimize or offset use of fossil fuels and associated GHG emissions in operations.
  4. Minimize water use in operations by optimizing water usage in site washing and maintenance activities.
  5. Conduct physical risk assessment to assess exposure to physical risk events such as storms or flooding, and maintain adequate project-level insurance to cover physical risks.
  6. Responsibly dispose of or recycle asset components at end of asset life.
  7. Conduct a customer survey and foster relationships with the local community and other stakeholders.

Human Resources

  1. Conduct employee survey to assess satisfaction and integrate feedback for continuous improvement.
  2. Maintain and distribute guidelines to employees regarding bribery & corruption, conflicts of interest, fraud, cybersecurity, data protection and privacy, and whistleblower protection.
  3. Invest in the development and growth of employees and monitor and promote inclusion and diversity at all levels of the company.

Executive Team

  1. Provide an annual update to the member committee on key ESG indicators and activities.
  2. Include ESG within corporate growth goals in the company business plan.
  3. Conduct and maintain an ESG Materiality and Risk Assessment to identify, assess and develop strategies to mitigate material ESG-related risks.
  4. Ensure that lobbying efforts and political contributions are targeted and appropriate.
  5. Define and publish shareholder rights in corporate documentation.
  6. Link ESG to executive compensation and establish a clear delegation of authority for ESG topics.

Scope and Responsibilities

This policy covers all CleanCapital business operations and applies to all employees, contractors, and suppliers. The Chief Commercial Officer is responsible for the oversight and implementation of this policy. The ESG Policy is reviewed and revised annually as required by the Executive Committee.

Julia Bell, Chief Commercial Officer
December 30, 2022