Capital and compliance are moving in the same direction. For investors and super funds with a stake in Australia’s biggest asset class – real estate – performance depends not only on carbon, but on how people are treated.
Sustainable finance accounted for 77 per cent (or USD $929 billion [$A1.31 trillion]) of total sustainable debt issuance in 2025, the highest proportion on record according to Westpac. Property is at the centre of the market, with some of the largest real estate loans in Australia tied directly to environmental and social performance.
As capital flows into sustainable finance, investors and super funds are under pressure to prove their ESG credentials in ways that go beyond carbon. Human rights and labour practices are also in the frame. But right now, there’s a gap: plenty of disclosure frameworks, very few practical tools.
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That’s where the Cleaning Accountability Framework (CAF) stands out. It connects labour conditions on the ground – cleaners’ pay, conditions, worker voice – to portfolio-level ESG reporting. For trustees and ESG officers, this is the difference between “paper ESG” and real impact.
CAF certification is already influencing tenant decisions. When the Australian Anti-Slavery Commission took space in Mirvac’s 577 Little Bourke Street in Melbourne, Commissioner Christopher Evans noted CAF certification was a “major consideration” in the decision.
Sam Apps, Mirvac’s group general manager for procurement and workplace, says CAF certification “has led to measurable improvements in working conditions and issue resolution, reinforcing our commitment to ethical, responsible and sustainable property management that protects workers’ rights”.
The anti-slavery commissioner has signalled his office will seek a Commonwealth procurement policy prioritising CAF-certified buildings for government leases. It’s the kind of mandate that could turn a voluntary framework into a market standard – and send a clear signal to asset owners that human rights performance is no longer optional and must go “beyond reporting”.
Proof in practice
The Australian Prudential Regulation Authority is alsosharpening expectations. Prudential Standard SPS 530 and CPS 230 make clear that trustees must manage ESG risks across their portfolios, including outsourced cleaning services.
IFM Investors, which finalised its acquisition of industry super fund property platform ISPT in 2025, is stewarding more than $233 billion on behalf of 762 institutional investors worldwide. IFM became the first asset owner to achieve full CAF portfolio certification across all eligible assets in its flagship core fund. The certification process included contract reviews, payroll checks, worker engagement and remediation when breaches with the standard were uncovered.
IFM Investors has set “a clear ‘flag on the hill’ target of 100 per cent CAF Certification”, says chief sustainability officer, Steven Peters. “Labour standards are a clear KPI for our $5.3 billion sustainability-linked loan program – one of the largest for any real estate manager in Australia – with CAF Certification one of the performance measures”.
By tying CAF certification to green finance, IFM Investors demonstrates how fair labour practices can directly influence the cost of capital.
Worker voice in action
Nearly 150,000 people work in commercial cleaning across Australia, many on temporary visas and often in isolation – making them especially vulnerable to exploitation. CAF certification provides year-on-year data, independent assurance for investors, and a clear signal to regulators. For workers, it provides a voice.
CAF’s Worker Engagement Program ensures cleaners are heard directly. Between 2019 and 2025, CAF investigated over 1200 compliance issues across the cleaning supply chains of 56 commercial assets – 70 per cent of them identified through direct worker engagement. The remainder were uncovered through desk-based assessments.
As Jennifer Alonso, CAF’s worker engagement officer and a former cleaner herself, puts it: “Cleaners often raise issues that building managers and investors don’t see. When those issues are taken seriously, it creates safer, fairer workplaces.” The most common issues raised are predictable: underpayment, insufficient training and heavy workloads.
Other issues are less obvious. At one building, cleaners raised heat stress during summer shifts after air-conditioning shut off at 5 pm, leaving floors stifling and airless. This triggered a joint solution: earlier shift starts, portable fans in hot zones, lighter uniforms, water stations, a heat-safety plan, and a mechanism to request after-hours cooling on nights of extreme heat. Owners and contractors signed off on systemic changes to a systemic risk raised by cleaners themselves.
The invitation to lead
The Responsible Investment Association of Australasia references CAF in its investment rationale and practical guide for managing human rights in value chains, and the property sector is starting to respond. Aside from IFM Investors’ full portfolio certification, Cbus Property has certified all eligible assets individually.
AustralianSuper, which invests directly in real estate and has around 90,000 members employed in the cleaning industry – has backed CAF since its inception in 2012.
The framework is here. The process is proven. The benefits are beginning to flow to workers, investors and asset owners. And as sustainable finance and prudential regulation converge, super funds have a mechanism to demonstrate that risks are being managed in the assets they own.
There is a clear reputational dividend. Many cleaners are members of the very super funds that own the buildings they clean. This creates a direct line between investment governance and member outcomes.
To be able to say, “your retirement savings are invested in assets certified as fair and safe for workers,” is proof that capital, compliance and people can be aligned.
