GRESB ICMA code of conduct statement

Statement of application of the ICMA code of conduct for ESG ratings and data products providers

GRESB B.V. (“GRESB”, or the “Group”) welcomes the International Capital Market Association (ICMA) Code of Conduct for ESG Ratings and Data Products Providers (the “Code”) and supports its objective to enhance transparency, governance, quality, and integrity in the ESG data ecosystem.

GRESB is a provider of ESG data products and benchmarks focused on real assets, including real estate and infrastructure. Our products are designed to provide standardized, comparable ESG performance data and insights to institutional investors and other stakeholders. Through its subsidiary Asset Impact, the Group also provides asset-level climate and emissions data, analytics, and forward-looking indicators. GRESB has reviewed the Code and confirms that it applies the principles of the Code in a manner proportionate to its business model, governance structure, and the nature of its ESG data products. This Statement of Application is structured in alignment with the six Principles of the ICMA Code to provide clear transparency on how each Principle is implemented across the Group’s ESG Ratings and ESG data products

1. Good governance

In line with Principle 1 (Good Governance), GRESB maintains governance arrangements designed to ensure the integrity, independence, and effective oversight of its ESG data products across both GRESB and Asset Impact.

• The Group operates under a clearly defined organizational structure with separation of responsibilities across data collection, validation, scoring, and product development functions.
• Governance and oversight frameworks apply across both assessment-based and data-driven products.
• Methodology development and product evolution are supported by internal controls and external stakeholder engagement.

Role of the GRESB Foundation

A key component of GRESB’s governance framework is the role of the GRESB Foundation, an independent, not-for-profit entity responsible for the oversight and evolution of the GRESB Assessments standards and methodologies. 

• The GRESB Foundation operates independently from GRESB’s commercial activities and is responsible for ensuring that the GRESB Standards remain robust, relevant, and aligned with market expectations and regulatory developments.
• The Foundation leads the standards-setting process, including consultation with industry stakeholders and subject matter experts.
• This structure provides an additional layer of independence between commercial operations and the development and evolution of methodologies, supporting objectivity and credibility.
• GRESB implements the standards and methodologies established through this independent process in its assessments and products. These arrangements enable GRESB to uphold high standards of accountability, transparency, and operational integrity.

2. Securing quality (systems and controls)

Consistent with Principle 2 (Securing Quality), GRESB has established policies, procedures, and systems designed to ensure the quality, consistency, and reliability of its ESG data products.

• GRESB Assessments rely primarily on participant-reported data collected directly from participating entities through structured assessments, supplemented where relevant by external benchmarked data such as industry benchmarks and decarbonization pathways.
• GRESB data validation processes include automated checks, manual review, and third-party validation options to enhance data accuracy and completeness.
• GRESB maintains internal controls, audit trails, and documentation supporting its outputs.
• When products and methodology are updated, we provide clear communication of methodology changes and their potential impact.
• Asset Impact products rely on asset-level datasets, publicly available data, and modelling methodologies to produce emissions and climate-related indicators.

These systems and controls support the delivery of high-quality, decision-useful ESG data.

3. Conflicts of interest

In accordance with Principle 3 (Conflicts of Interest), GRESB is committed to identifying, managing, and mitigating actual or potential conflicts of interest.

• Policies and procedures are in place to safeguard the independence and objectivity of ESG assessments and outputs.
• Governance and operational structures are designed to separate commercial activities from methodological development and scoring processes.
• GRESB does not allow commercial relationships with participants or partners to influence assessment outcomes.
• Relevant conflicts of interest and mitigation measures are disclosed transparently where appropriate.

These measures support the credibility and impartiality of GRESB’s ESG rating and benchmarking products.

4. Transparency

In line with Principle 4, transparency is a core principle of GRESB’s approach.

• GRESB publicly discloses its methodologies, including scoring frameworks, indicators, and weighting structures, enabling users to understand how results are derived.
• The purpose, scope, and limitations of GRESB Assessments and Benchmarks are clearly described.
• GRESB provides detailed guidance to participants and users on data requirements, scoring logic, and interpretation of results.
• Methodology updates are communicated transparently, including rationale and expected impacts.

GRESB balances transparency with the protection of proprietary methodologies and confidential data.

5. Confidentiality

In line with Principle 5, GRESB maintains robust policies and controls to protect confidential and non-public information.

• Data submitted by participants is treated in accordance with strict confidentiality protocols and used solely for purposes related to GRESB products.
• Asset Impact applies data governance controls to ensure appropriate use and protection of sensitive data inputs.
• Access controls, data governance policies, and technical safeguards are implemented to protect sensitive information.
• Aggregation and anonymization techniques are applied where appropriate to prevent identification of individual entities in public outputs.

These measures ensure trust in the handling of participant data with integrity and confidentiality.

6. Engagement

Consistent with Principle 6, GRESB actively engages with both data providers (participants) and users of its ESG data products.

• GRESB provides clear timelines, guidance, and support to participants throughout the annual assessment process.
• Participants are given the opportunity to review submitted data, respond to validation queries, and flag potential errors before results are finalized.
• GRESB maintains dedicated communication channels for participant and user inquiries.
• Stakeholder feedback is incorporated into ongoing methodology development and process improvements.

GRESB aims to ensure that its information-gathering processes are efficient, transparent, and responsive, while maintaining the independence of its assessments.

GRESB applies the Code in a manner consistent with its role as a provider of:

• Assessment-based ESG benchmarks; and
• Data-driven ESG and climate analytics (including Asset Impact).

This includes proportionate application of the Principles where product characteristics differ, particularly where:

• Products do not constitute ESG ratings or scores;
• Data is modelled or derived rather than collected through direct engagement;
• Outputs are designed as datasets or indicators rather than opinions or rankings.

This approach reflects the flexible, principles-based nature of the Code.

GRESB will review this Statement of Application at least annually and update it as appropriate to reflect developments in its practices, products, and regulatory expectations.