Civitas Social Housing PLC (Civitas) is the UK’s first social housing and healthcare Real Estate Investment Trust (REIT) launched on the London Stock Exchange in November 2016. We raise capital at large-scale from institutional and retail investors and use the funds raised to buy properties to be rented as social and care-based community housing for the long-term. Our objective is to help tackle the chronic shortage of social and care-based community housing in the UK, with a current focus on supported housing for vulnerable adults.

Civitas is committed to a continuous improvement process in our approach to Environmental Social Governance (ESG) integration into our investment processes. This document sets out the current commitments we have made to integrate ESG considerations in our investment strategy. Over time, we envisage that this Policy will advance in response to business practices and structures changes, technological innovation, and legal requirements. We will closely monitor this Policy and seek to review on an annual basis.

Our Investment Strategy

Civitas’ impact goal is to increase the provision of high-quality social and care-based community housing that delivers positive social outcomes. Our investments are structured with the intention of delivering both financial returns and measurable large-scale social impact. This is achieved by meeting the needs of vulnerable individuals and providing long-term, high-quality specialist housing to enable them to live as part of existing communities rather than within large, often remote institutions.

As an objective, success is measured by enabling individuals to enjoy better life outcomes. We work with leading independent consultants to measure and validate the extent of the social impact/ESG and social value that our investing activities have created. This includes not just the actual level of cost savings for the public purse which have been assessed independently but the measurable benefits that have accrued to each individual who now resides in a Civitas adapted property. These benefits range from direct improvements to health and wellbeing, thereby allowing greater independence, to more personal measures such as a reduction in isolation and improved happiness. All transactions have to meet both social and economic objective.

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Approach to ESG


Civitas seeks to ensure the environmental efficiency and sustainability of its properties. Environmental considerations are integrated into our investment processes and decisions. In conjunction with our Housing Association partners and Care Providers long term operations will be managed to minimise impact on the environment.

We will:

  1. Ensure continued relevance and effectiveness of our sustainability strategy and plan, including associated policies;

  2. Incorporate expected environmental standards and reporting in contracts and leases;

  3. Seek to improve the environmental performance of our portfolio explore initiatives to achieve zero carbon across all properties by 2030 through deep retrofit programmes working with national partners to bring about enhancements utilising available government grants and support

Prior to the acquisition of any property, we will

  • evaluate the historic use of the site and identify issues including possible ground contamination, presence of hazardous materials, flooding risk, etc;

  • review the energy efficiency as part of our due diligence process ensuring a compliant energy performance certificate has been obtained;

  • carefully examine the prospect of achieving environmental improvements to non-compliant properties through enhancement works;

  • ensure funding is in place with a plan for carrying out any improvements, including environmental efficiency measures e.g. enhancing insulation and upgrading windows.

Post-acquisition, we will

  • commission an independent survey of each property to ensure all properties are renovated and then maintained to high-quality standards;

  • monitor the energy efficiency performance grades and explore the possibility of improving the future energy efficiency of homes e.g. through investing in solar technology where it may be beneficial.


As a responsible impact investor, we aim to deliver positive social impact alongside a financial return. Impact investing is an integral part of our purpose, with social impact and social value objectives embedded in our business model.

Our social impact investment activities address the critical challenge of addressing the needs and aspirations of vulnerable individuals with a range of physical or learning disabilities and their families. We seek to provide homes in well-established communities with 24/7 care available on site, with more independence than they would be afforded in a residential home.

We will continue to maintain our accreditation as an impact investor under International Finance Corporation (IFC) Principles and deliver social impact that extends externally to include the Civitas Partnerships. In addition to focusing on positive outcomes for tenants, the social implications of our acquisitions are considered from two dimensions – quality of care and value for money.

We will:

  • aim to increase supply of social housing that offers significant cost-savings to the public purse compared to alternative settings but with high quality social care delivery;

  • benchmark 100% of rents and also commission independent rent reviews for all properties to ensure rents are affordable and fair value;

  • check the CQC ratings of all Care Providers to ensure they are rated Good or Outstanding;

  • build direct relationships with Care Providers and carry out site visits to talk to Care Providers and residents;

  • contribute to improved health outcomes and wellbeing of individual tenants, living in the homes we provide, thereby allowing greater independence, to more personal measures such as a reduced social isolation, increased confidence and self-esteem, and improved happiness;

  • Increase employability skills and aspirations of individual tenants;

  • work with our specialist Housing Association partners and Care Providers who are experienced in working with adults with complex support needs to ensure that appropriate property adaptations are undertaken to meet individual vulnerable tenant needs;

  • monitor the Value for Money reports produced by our Housing Association partners for the Regulator of Social Housing;

  • actively encourage builders to offer apprenticeships and employment to locals during construction or improvement works;

  • reduced costs associated with welfare benefits, crime, social services, education, etc.


We operate in compliance with the UK Corporate Governance Code and carry out our business with authenticity and integrity. The Board is made up of non-executive directors who regularly review the effectiveness of systems in place and maintain overall control of any changes to the capital, corporate or management structure. They are also responsible for risk management, including financial operations and compliance.

Our driving values are:

  1. Transparency and openness;

  2. Preparedness to communicate failures and lessons learned;

  3. Willingness to obtain independent perspective.

These values are underpinned by putting in place policies which address share dealing; bribery prevention; whistleblowing; diversity; environmental and sustainability; communications including procedures for the release of price sensitive information and public interest disclosures; corporate social responsibility; charitable donations; and Code of Business Conduct and Ethics.

We prepare comprehensive reports and engage with our stakeholders all through the year. Semi-annual assessments of our impact and ESG performance is undertaken by independent specialist social impact consultants.

In addition, we will:

  • carry out due diligence of the governance structure and management team of all potential partner Housing Associations;

  • monitor adherence of our Housing Associations partners to their adopted a code of governance (mostly the National Housing Federation code) at regular engagement meetings;

  • in conjunction with Housing Associations partners, encourage adoption of the Civitas Best Practice Protocol that has been designed to safeguard the long-term financial strength and social delivery of Housing Associations and the supported housing they provide, whilst also bringing a measure of consistency in standards and investor relations to the Specialist Supported Housing sector as a whole;

  • instigate formal engagement meetings with Housing Association partners on a quarterly basis to share and receive updates on operational performance – occupancy rates, property compliance matters, and health and safety – whilst also providing advice around future growth and shared learning.


ESG Integration

ESG integration is the clear inclusion of ESG factors in our investment decisions, based on a systematic process and appropriate research sources, in a way that mitigates ESG risks and capitalises on ESG opportunities. The outcome of our research and analyses will place mandatory constraints on our investments.

We aim to integrate social impact and ESG considerations into all stages of the investment process. The Investment Diagram (below) illustrates how these are integrated using a rigorous due diligence process and portfolio monitoring approach. This process is aligned with the IFC’s Operating Principles for Impact Management and designed to ensure impact investing maintains high standards of impact integrity.


UN Sustainable Development Goals

The 17 Sustainable Development Goals were adopted by all UN Member States in 2015, as part of the 2030 Agenda for Sustainable Development which set out a 15-year plan to achieve the Goals. They are integrated and indivisible and balance the three dimensions of sustainable development: economic, social and environmental.

Through raising long-term equity for the social housing sector, Civitas will continue to support the UN Sustainable Development Goals and currently directly/indirectly contribute to the following:

  • Goal 11: “Make cities and human settlements inclusive, safe, resilient and sustainable.”

  • Goal 17: “Strengthen the means of implementation and revitalise the Global Partnership for Sustainable Development.”

  • Goal 13: *Take urgent action to combat climate change and its impact.”

  • Goal 3: “Ensure Healthy lives and promote well-being for all at all ages.”

  • Goal 1: “End poverty in all its forms everywhere.”

  • Goal 7: “Ensure access to affordable, reliable, sustainable and modern energy for all.”

  • Goal 8: “Promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all.”

There is good evidence that positive outcomes relating to one SDG can cause positive outcomes relating to other SDGs. In the case of Civitas, funding the delivery of social housing for vulnerable individuals with a care need is evidenced to have secondary benefits relating to several other SDGs. We will strive to expand the opportunity to contribute to these SDG Linkages.


Measurement and Reporting

Active stewardship of our investments is central in governance and decision making to optimise impact. The extent to which our investments generate the desired positive intentional social and environmental outcomes alongside competitive financial returns are continually monitored. The Impact Assessment process involves setting and agreeing the relevant metrics and measures which will provide the required insight to assess performance for each Impact Objective, as set out in Civitas Theory of Change.

On a semi-annual basis, the independent impact advisor carries out the required data analysis, as well as conducting interviews, undertaking site visits and tenant surveys so that an assessment for each Impact Objective can be formed. The analysis of Civitas’ social impact is aligned with the five dimensions of impact as set out by the Impact Management Project (see box below) – a widely recognised and established approach to impact management.


The Sustainable Development Goals (SDGs) will also provide a recognised and useful framework for assessing Civitas’ contribution towards economic, social and environmental development. The independent impact advisor will draw on indicators set out by the UN for each SDG, as well as aligning existing proxy measures to the relevant UN indicators to assess Civitas’ alignment and strength of contribution to each SDG. The independent reports are and will continue to be published.


The Board retains overall responsibility for the ESG Policy. This duty is undertaken on behalf of the Board by the Investment Manager who is responsible for and committed to its implementation. An annual review of the ESG approach will be undertaken and updated.