Report - COP Prototype

2022 Communication on Progress

BBGI Global Infrastructure S.A.

Published date

June 30, 2022

No. of questions

Supplemental files

BBGI Global Infrastructure S.A._ESG Report_2021.pdf BBGI Global Infrastructure S.A._ESG Report_2021.pdf

CEO Statement

Signed

Governance

Policies and Responsibilities

1. Does the Board / highest governance body or most senior executive of the company:

Issue an annual statement about the relevance of sustainable development to the company

Issue an annual statement that addresses impacts on both people and the environment

Issue an annual statement highlighting a zero tolerance for corruption

Sign off on organizational sustainability targets

Supervise Environmental, Social, and Governance reporting

Regularly review potential risks related to the business model

None of the above

2. Does the company have a publicly stated commitment regarding the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a commitment within 2 years	Yes, and the commitment is focused on our own operations	Yes, and the commitment includes our own operations and the value chain	Yes, and the commitment includes our own operations and the value chain along with communities and society
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Disclaimer: Across this survey, we define our 'supply chain' and 'business relationships' as being the special purpose company ('Portfolio Companies') that entered into a project agreement with our clients and various drop-down agreements with material 'Subcontractors'. Subcontractors which provide services to the underlying Portfolio Companies including the Facilities Management provider and the Operations and Management provider are excluded unless specifically mentioned. See sections ‘Fair employment and remuneration’ in our ESG Report page 47, ‘Governance framework at our portfolio companies’ in our ESG Report page 53, ‘Environment & climate change’ in our ESG Report page 21 and ‘Business ethics and integrity’ in our ESG Report page 56. [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf] For further details, please also see our Modern Slavery Act statement, the latest for which can be found at: www.bb-gi.com/investors/policies/modern-slavery/

3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a code of conduct within two years	Yes, focused on employee conduct	Yes, focused on employees and suppliers	Yes, focused on employees, suppliers, and other business relationships
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

See section ‘Governance framework at our portfolio companies’ in our ESG Report page 53. [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf] For further details, please also see our Modern Slavery Act statement, the latest for which can be found at: www.bb-gi.com/investors/policies/modern-slavery/. BBGI has set environmental commitments, see section ‘Environment & climate change’ in our ESG Report page 21.

4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

	No one is specifically responsible for this topic	Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)	Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)	Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights	Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

All related policies and commitments are reviewed and approved by the Management Board.

5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

	No formal structure	Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)	Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)	Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)	Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

The Management Board has established an executive-led ESG Committee, comprising the Co-CEOs, the CFO, the ESG/Sustainability Director and the Corporate Secretary to govern all sustainability topics. See section ‘ESG governance’ in our ESG Report page 52. [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf]

Prevention

6. Does the company have a process or processes to assess risk?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

For Human rights risks and labour rights risks, please see section ‘Fair employment and remuneration’ in our ESG Report page 47 and ‘Governance framework at our portfolio companies’ on page 53. For Environmental risks, please see section 'Task Force on Climate-Related Financial Disclosure' in our ESG Report page 25. For corruption risks, please see sections ‘Business ethics and integrity’ on page 56. [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf]

6.1. During the assessment of risk, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

Please see section 'Governance framework at our portfolio companies' in our ESG Report page 53 and 'Proprietary ESG KPI survey' page 54. [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf]

7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

Please see section ‘Fair employment and remuneration’ in our ESG Report page 47, ‘Governance framework at our portfolio companies’ on page 53, ‘Business ethics and integrity’ on page 56 and 'Approach to responsible investment' on page 10. [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf]

7.1. During the due diligence process, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Concerns and grievance mechanisms

8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

No, this is not a current priority

No, but we plan to within two years

Yes, we have an informal process (e.g., through supervisors, others)

Yes, we have a formal process

Optional comment

Please see section 'Whistleblowing Policy and hotline' in our ESG Report page 47. [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf], our Whistleblowing page [https://www.bb-gi.com/investors/policies/bbgi-s-whistleblowing-hotline/] and our Whistleblowing policy: [https://www.bb-gi.com/media/2094/whistleblowing-policy-v21-approved-sb-270122-_clean.pdf]

8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

	No	Yes
Is the process communicated to all employees/workers in local languages?
Is the process available to non-employees (e.g., contractors, vendors, suppliers)?
Is the process confidential (e.g., whistleblowing process)?
Are there processes in place to avoid retaliation?
Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)
Other (Please provide additional information)

Optional comment

Please see section 'Whistleblowing Policy and hotline' in our ESG Report page 47. [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf] and [https://www.bb-gi.com/investors/policies/bbgi-s-whistleblowing-hotline/]

9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

	No process to enable remedy to stakeholders	Remedy available to some stakeholders (i.e., some geographies, employees only)	Remedy is available to all affected stakeholders	Remedy is available to all stakeholders, and suppliers are expected to have similar policies
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Please see section 'Whistleblowing Policy and hotline' in our ESG Report page 47. [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf]. BBGI implements a Whistleblowing Policy across its Portfolio Companies as part of its standard set of policies. Please see section 'ESG governance' in our ESG Report page 47. [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf].

Lessons

10. How does the company capture lessons regarding each of the following sustainability topics?

	No lessons are regularly captured	Conducts root cause analyses/investigation of major incidents	Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly	Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Executive Pay

11. Is executive pay linked to performance on one or more of the following sustainability topics?

Optional comment

In line with our ESG principles, the Company includes ESG metrics in the short-term incentive plan (‘STIP’) for the Management Board to ensure that the Company continues to produce positive non-financial returns. The STIP is based on a balance of strategic, financial, operational, compliance and ESG/Health and Safety metrics with robust quantitative and qualitative performance requirements set for threshold, target and maximum performance. Please see section 'Remuneration at a Glance' in our Annual Report page 72: https://www.bb-gi.com/media/2123/bbgi-fy2021-annual-report.pdf#page=74

Board Composition

12. Percentage of individuals within the company’s Board / highest governance body by:

	Number/Percentage	Not applicable (Please provide additional information)
Total number of board members (#)	7
Male (%)	71
Female (%)	29
Non-binary (%)	0
Under 30 years old (%)
Currently not reported.
30-50 years old (%)
Currently not reported.
Above 50 years old (%)
Currently not reported.
From minority or vulnerable groups (%)	0
Executive (%)	43
Independent (%)	57

Optional comment

Please see section 'Gender diversity at BBGI' in our ESG Report page 48. [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf]

Data Assurance

14. Is the information disclosed in this questionnaire assured by a third-party?

No assurance for any metrics

Limited assurance for minority of metrics (e.g., GHG emissions only)

Please see appendix 'GHG Protocol' in our ESG Report page 62

Limited assurance for majority of metrics

Reasonable assurance for minority of metrics

Please see appendix 'GHG Protocol' in our ESG Report page 62 and section 'Task Force on Climate-Related Financial Disclosure' on page 25.

Reasonable assurance for majority of metrics

Other (Please provide additional information)

Human Rights

Commitment

2.1. For each human rights policy, is it:

	Aligned with international human rights standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving human rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of expression
Digital security / privacy
Our materiality assessment performed enabled us to identify sustainability issues that are priorities for our stakeholders and where our impact is most significant. Although, we do not consider 'Digital security / privacy' as creating potential salient negative impacts towards human rights in our operations and/or across our supply chain, we did identify'Digital security / privacy' as one of our material governance topics. More details in our ESG Report on page 58: [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf].
Rights of women and/or girls
Access to culture
Rights of indigenous peoples
Free, prior and informed consent
Rights of refugees and migrants
Access to water and sanitation

Response

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

BBGI supports and upholds the protection of internationally proclaimed human rights and ensures that the Company is not complicit in human rights abuses in our supply chain. See section ‘Fair employment and remuneration’ in our ESG Report page 47 and ‘Governance framework at our portfolio companies’ on page 53. [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf]

Labour

Commitment

1. Does the company have a policy commitment in relation to the following labour rights principles?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
The right to freedom of association and the effective recognition of the right to collective bargaining are legally protected rights in Luxembourg and in the countries where we operate. BBGI has no policy to restrict those rights.
Forced labour
2021
Child labour
2021
Non-discrimination in respect of employment and occupation
2021
Occupational safety and health
2021
Working conditions (wages, working hours)

1.1. For each labour rights policy, is it:

	Aligned with international labour standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving labour rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks /impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
The right to freedom of association and the effective recognition of the right to collective bargaining are legally protected right in Luxembourg and in the countries where we operate. BBGI has no policy to restrict those rights.
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
In 2021, we implemented a new Responsible Contractor Policy describing our commitment to ensuring high standards of environmental, social and governance performance within our supply chain. Please see section 'Governance framework at our portfolio companies' in our ESG Report page 53.
Child labour
In 2021, we implemented a new Responsible Contractor Policy describing our commitment to ensuring high standards of environmental, social and governance performance within our supply chain. Please see section 'Governance framework at our portfolio companies' in our ESG Report page 53.
Non-discrimination in respect of employment and occupation
In 2021, we implemented a new Responsible Contractor Policy describing our commitment to ensuring high standards of environmental, social and governance performance within our supply chain. Please see section 'Governance framework at our portfolio companies' in our ESG Report page 53.
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

Please see section 'Health and safety' in our ESG Report page 46. [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf].

4. Who receives training for the following labour rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
The right to freedom of association and the effective recognition of the right to collective bargaining are legally protected right in Luxembourg and in the countries where we operate. BBGI has no policy to restrict those rights.
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Performance

6. What is the percentage of employees covered under collective bargaining agreements?

	Percent of employees (%)	Unknown
Employees covered under collective bargaining (%)	0

Optional comment

The right to freedom of association and the effective recognition of the right to collective bargaining are legally protected right in Luxembourg and in the countries where we operate. BBGI has no policy to restrict those rights.

7. What is the percentage of employees in a trade union or other workers' organization?

	Percent of employees (%)	Unknown	Not applicable (Please provide additional information)
Employees in a trade union or on a worker committee (%)	0

Optional comment

8. In the course of the reporting period, what was the percentage of women in:

	Percent of women (%)	Unknown
Senior leadership level position	0
Non-executive board	50

Optional comment

Please see section 'Gender diversity at BBGI' in our ESG Report page 48.

9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

	Salary ratio (%)	Unknown	Choose to not disclose
Women / Men (%)
Not disclosed for confidentiality reasons, the small size of our team would identify individuals.

10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

	Frequency of injury	Unknown	Choose to not disclose
Frequency of injury
10 lost time incidents across our portfolio of 54 assets. Please see section 'Health and safety' in our ESG Report page 46. [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf]

11. In the course of the reporting period, what was the company’s incident rate?

	Incident rate	Unknown	Choose to not disclose
Incident rate
10 lost time incidents across our portfolio of 54 assets. Please see section 'Health and safety' in our ESG Report page 46. [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf]

Response and Reporting

12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
The right to freedom of association and the effective recognition of the right to collective bargaining are legally protected right in Luxembourg and in the countries where we operate. BBGI has no policy to restrict those rights.
Forced labour
No material adverse impact reported during the reporting period.
Child labour
No material adverse impact reported during the reporting period.
Non-discrimination in respect of employment and occupation
No material adverse impact reported during the reporting period.
Occupational safety and health
Working conditions (wages, working hours)

13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

BBGI upholds the principles of freedom of association and the right to collective bargaining in our business and in our supply chain. The right to freedom of association and the effective recognition of the right to collective bargaining are legally protected right in Luxembourg and in the countries where we operate. BBGI has no policy to restrict those rights. BBGI does not, and will not, tolerate any form of slavery, human trafficking or forced labour. BBGI is committed to ensuring there is transparency within our business, and to preventing slavery and human trafficking in its corporate activities, day-to-day operations and in our supply chain. At BBGI we are an equal opportunity employer and have zero tolerance for any form of workplace discrimination. Please see our ESG Report. [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf]

Environment

Commitment

1. Does the company have a formal policy on the following environmental topics?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Climate Action
2022
Water
Across our portfolio we introduced an enhanced ESG Best Practice Guide which is designed to support the implementation of BBGI’s ESG & Sustainability strategy across all its portfolio companies. This guide and includes an upgraded proprietary ESG KPI survey covering all aspects of our ESG oversight, including water usage and water recycling.
Oceans
Forests / Biodiversity / Land Use
2021
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Across our portfolio we introduced an enhanced ESG Best Practice Guide which is designed to support the implementation of BBGI’s ESG & Sustainability strategy across all its portfolio companies. This guide and includes an upgraded proprietary ESG KPI survey covering all aspects of our ESG oversight, including waste management.
Energy & Resource Use
Across our portfolio we introduced an enhanced ESG Best Practice Guide which is designed to support the implementation of BBGI’s ESG & Sustainability strategy across all its portfolio companies. This guide and includes an upgraded proprietary ESG KPI survey covering all aspects of our ESG oversight, including energy and resource use.

Optional comment

Please see section 'Environment & climate change' in our ESG Report page 21 [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf] and our ESG Policy [https://www.bb-gi.com/media/2039/20210310-esg-and-sustainability-risk-policy-sfdr-final.pdf].

1.1. For each environmental policy, is it:

	Aligned with international environmental standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving environmental expertise from inside and outside the company?	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks/ impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

Please see section 'Proprietary ESG KPI survey' in our ESG Report page 54. [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf]

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Climate Action
We developed a Net Zero Plan, which details the targets, metrics and pathways of our Corporate Emissions and our Financed Emissions. In 2021 we engaged a climate modelling specialist firm to undertake a detailed review of all our infrastructure investments, to consider how both physical and transition risks could impact our investments due to climate change. Across our portfolio we introduced an enhanced ESG Best Practice Guide which is designed to support the implementation of BBGI’s ESG & Sustainability strategy across all its portfolio companies. This guide and includes an upgraded proprietary ESG KPI survey covering all aspects of our ESG oversight, including GHG emissions.
Water
Across our portfolio we introduced an enhanced ESG Best Practice Guide which is designed to support the implementation of BBGI’s ESG & Sustainability strategy across all its portfolio companies. This guide and includes an upgraded proprietary ESG KPI survey covering all aspects of our ESG oversight, including water usage and water recycling.
Oceans
Forests / Biodiversity / Land Use
In 2022 we plan to roll-out a new Biodiversity Policy at all our portfolio companies. The objective of this Biodiversity Policy is to provide a set of high-level principles and best practice standards for the preservation of biodiversity, ecosystems and natural habitats directly affected by the built assets managed by our portfolio companies.
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Across our portfolio we introduced an enhanced ESG Best Practice Guide which is designed to support the implementation of BBGI’s ESG & Sustainability strategy across all its portfolio companies. This guide and includes an upgraded proprietary ESG KPI survey covering all aspects of our ESG oversight, including waste management.
Energy & Resource Use
Across our portfolio we introduced an enhanced ESG Best Practice Guide which is designed to support the implementation of BBGI’s ESG & Sustainability strategy across all its portfolio companies. This guide and includes an upgraded proprietary ESG KPI survey covering all aspects of our ESG oversight, including energy & resource use.

4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Climate Action
Water
Across our portfolio we introduced an enhanced ESG Best Practice Guide which is designed to support the implementation of BBGI’s ESG & Sustainability strategy across all its portfolio companies. This guide and includes an upgraded proprietary ESG KPI survey covering all aspects of our ESG oversight, including water usage and water recycling.
Oceans
Forests / Biodiversity / Land Use
In 2022 we plan to roll-out a new Biodiversity Policy at all our portfolio companies. The objective of this Biodiversity Policy is to provide a set of high-level principles and best practice standards for the preservation of biodiversity, ecosystems and natural habitats directly affected by the built assets managed by our portfolio companies.
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Across our portfolio we introduced an enhanced ESG Best Practice Guide which is designed to support the implementation of BBGI’s ESG & Sustainability strategy across all its portfolio companies. This guide and includes an upgraded proprietary ESG KPI survey covering all aspects of our ESG oversight, including waste management.
Energy & Resource Use
Across our portfolio we introduced an enhanced ESG Best Practice Guide which is designed to support the implementation of BBGI’s ESG & Sustainability strategy across all its portfolio companies. This guide and includes an upgraded proprietary ESG KPI survey covering all aspects of our ESG oversight, including energy & resource use.

4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?

	Description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)
Climate Action	BBGI became a signatory to the Net Zero Asset Managers Initiative and commits to support the goal of net zero greenhouse gas (‘GHG’) emissions by 2050, in line with global efforts, to limit warming to 1.5°C (‘net zero emissions by 2050 or sooner’). We also commit to supporting investing aligned with net zero emissions by 2050 or sooner. We developed a Net Zero Plan, which details the targets, metrics and pathways of our Corporate Emissions and our Financed Emissions. In 2021 we engaged a climate modelling specialist firm to undertake a detailed review of all our infrastructure investments, to consider how both physical and transition risks could impact our investments due to climate change. Across our portfolio we introduced an enhanced ESG Best Practice Guide which is designed to support the implementation of BBGI’s ESG & Sustainability strategy across all its portfolio companies. This guide and includes an upgraded proprietary ESG KPI survey covering all aspects of our ESG oversight, including GHG emissions. Please see section 'Environment & climate change' in our ESG Report page 21. [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf]
Energy & Resource Use	BBGI has begun the process of collecting the required information and will report against SFDR Principal Adverse Sustainability Impact indicators and will publish its Principal Adverse Impact statement. Please see section 'Sustainable Finance Disclosure Regulation (SFDR)' in our ESG Report page 43. [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf]
Water	BBGI has begun the process of collecting the required information and will report against SFDR Principal Adverse Sustainability Impact indicators and will publish its Principal Adverse Impact statement. Please see section 'Sustainable Finance Disclosure Regulation (SFDR)' in our ESG Report page 43. [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf]
Forests / Biodiversity / Land Use	BBGI has begun the process of collecting the required information and will report against SFDR Principal Adverse Sustainability Impact indicators and will publish its Principal Adverse Impact statement. Please see section 'Sustainable Finance Disclosure Regulation (SFDR)' in our ESG Report page 43. [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf]
Air Pollution	BBGI has begun the process of collecting the required information and will report against SFDR Principal Adverse Sustainability Impact indicators and will publish its Principal Adverse Impact statement. Please see section 'Sustainable Finance Disclosure Regulation (SFDR)' in our ESG Report page 43. [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf]
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)	BBGI has begun the process of collecting the required information and will report against SFDR Principal Adverse Sustainability Impact indicators and will publish its Principal Adverse Impact statement. Please see section 'Sustainable Finance Disclosure Regulation (SFDR)' in our ESG Report page 43. [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf]
Oceans

4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?

	Progress is reviewed against goals annually or more frequently	Progress is reported internally to the most senior level	Progress is reported externally	Other (Please provide additional information)
Climate Action
Energy & Resource Use
Water
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Oceans

Optional comment

Please see section 'Sustainable Finance Disclosure Regulation (SFDR)' in our ESG Report page 43. [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf] and section

5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Climate Action
No material adverse impact reported during the reporting period.
Water
No material adverse impact reported during the reporting period.
Oceans
Not applicable.
Forests / Biodiversity / Land Use
No material adverse impact reported during the reporting period.
Air Pollution
No material adverse impact reported during the reporting period.
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
No material adverse impact reported during the reporting period.
Energy & Resource Use
No material adverse impact reported during the reporting period.

Climate Action

6. What were the company’s gross global greenhouse gas emissions for the reporting period?

Scope 1 Emissions

Full

None

Emissions (tCO2e)

Scope 2 Emissions

Full

None

Emissions (tCO2e)

Scope 3 Emissions

Full

Partial

None

Emissions (tCO2e)

Optional comment

Scope 1 = 13.4 tCO2e / Scope 2 = 7.2 tCO2e / Scope 3 = 57.71 tCO2e. Please see appendix 'GHG Protocol' in our ESG Report page 62. [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf]

7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

Percent of revenue (%)

Unknown

Not applicable (Please provide additional information)

Investment in R&D is not applicable to BBGI.

8. Has the organization acted to support climate change adaptation and resilience?

We have taken action to increase organization-wide resilience to climate change

We have taken action to increase resilience in our supply chains

We have taken action to increase resilience in the communities in which we operate

We have provided funding for climate change adaptation and resilience initiatives and projects

We have not taken actions to build climate change resilience in the reporting period

Other (Please provide additional information)

Unknown

Optional comment

Please see section 'Environment & climate change' in our ESG Report page 21. [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf]

Energy / Resource Use

9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

% of total energy consumption

Unknown

Optional comment

BBGI reached out to our landlord to enquire about renewable energy options, which are currently not available for our building. We will continue to follow-up and investigate for alternatives on an annual basis.

Technology

10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

Percent of total revenue (%)

Unknown

Not applicable (Please provide additional information)

Our purpose is to provide access to a diversified portfolio of essential social infrastructure investments that generate long-term, sustainable returns and serve an inherent social purpose.

Overall Environment

21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

Please see our ESG Report. [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf]

Anti-corruption

Commitment

1. Does the company have an anti-corruption compliance programme?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes

2021

2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

No, and we have no plans to develop a policy

No, but we plan to in the next two years

Yes, included within a broader policy

Yes, articulated as a stand-alone policy

Prevention

3. Who receives training on anti-corruption and integrity?

3.1. How often is such training provided?

	One time only	Every year	Every two or more years	We do not collect this data
All employees
Select employees
Contractors
Direct suppliers of the organization
Other – such as partners, clients, etc.
Indirect suppliers of the organization

4. Does the company monitor its anti-corruption compliance programme?

No, we do not monitor the anti-corruption compliance programme

Review issues on ad-hoc basis

Yes, through internal employee self-evaluations

Yes, through automated controls monitoring

Yes, through external independent monitoring

Yes, through other mechanisms

BBGI encourages all Employees to report all incidents of actual or suspected breach of our Code of Conduct to their superior, the Management Board or the Compliance Officer.

Response and Reporting

5. Please report the company's total number and nature of incidents of corruption during the reporting year.

	Number of incident(s)	Unknown	Choose to not disclose
Confirmed during the current year, but related to previous years	0
None
Confirmed during the current year, and related to this year	0
None

6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

Initial case assessment

Internal investigation

Review by risk / ethics committee

Review by board of directors

External audit / review

Other (please provide additional information)

Not applicable/no incidents in the reporting period

Optional comment

Please see section 'Business ethics and integrity' in our ESG Report page 56.

7. Does your company engage in Collective Action against corruption?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes (please explain)

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

Please see our ESG Report. [https://www.bb-gi.com/media/2127/bbgi-esg-report-2021.pdf]