Scope and Reporting Boundaries

Statement

Cromwell Property Group reports sustainability performance on an annual financial year ending 30 June and in accordance with the GRI for core reporting. For details on GRI please visit www.globalreporting.org The last previous report produced was dated 30 June 2018

Reporting includes Cromwell Property Group, corporate sustainability activities, balance sheet property assets in Australia, Australian retail funds, and European funds management including assets managed on behalf of the Cromwell European REIT (SGX:CNNU).

Reporting does not cover other operational businesses where Cromwell does not have majority ownership (Oyster Group, Phoenix Portfolios, LDK Healthcare) Additionally, several funds managed by Cromwell do not have a mandate that supports sustainability initiatives and reporting.

Similarly, within some directly owned property assets, tenants hold a lease and full management control over the operations of the entire asset that they occupy. For these assets Cromwell does not have the capacity to set sustainability policy or directly implement change.

Participation and disclosure of consumption and performance data for these assets is wholly dependent upon the willingness and capacity of those investors and tenants to support Cromwell’s sustainability reporting objectives. Moreover, different leasing and reporting standards and funds with significant asset acquisition and disposal profiles across countries, further restricts capacity to collect and uniformly disclose comparable operational data.

As the breadth of reporting increases, comparability becomes more challenging, particularly across active funds where regular transactions occur. To this end Cromwell continues to collect more data and provide greater transparency on how and where data is collected as well as the policies and risk measures they are applied against. Key indices such as GRESB and DJSI are also used to provide verification on performance as well as benchmarking against peers.

In our efforts to better respond to our stakeholder expectations and information needs we have committed to improve the level of transparency and enhance the reliability of our reporting. As part of this commitment, in the future we will seek third party independent assurance over our non-financial reporting.

To assess the assurance readiness of our non-financial data management, we engaged Ernst & Young (EY) to conduct a pre-assurance advisory engagement to assess a selection of our non-financial indicators and objectives. We asked EY to assess indicators in line with our Pillars (as presented on page XX).

Although EY was not been engaged to provide assurance on our non-financial disclosures, it identified areas where we can take action to improve our reporting processes, which we hope to implement as we move towards external assurance in the coming years