Corporate Social Responsibility Report 2019 | Cushman & Wakefield

OUR IMPACT ON OPERATIONS Cushman & Wakefield operates out of approximately 400 offices in 60 countries, with more than 53,000 employees serving clients worldwide. With such a large footprint, it’s critical that we work with integrity at all times, asking our employees to adhere to a rigorous Ethics and Compliance program year-round. Whether our focus is on human rights, health and safety, anti-corruption or supply chain management, we remain committed to consistently doing the right thing for our clients, employees and suppliers. It’s important we do the right thing for the environment as well. As such, we remain focused on continually measuring and managing environmental performance and practices in our operations and improving them over time.

ETHICS AND COMPLIANCE As one of the world’s leading commercial real estate services firms, we hold ourselves to the highest standards of corporate integrity and strive to create a culture in which everyone acts out of personal accountability for protecting our business, our reputation, our commitments to our Board of Directors, our clients and all those we serve. We aim to uphold all applicable laws and regulations affecting our business around the world without exception and to uphold our own standards of ethical behavior. By protecting our industry-leading reputation, built over more than 100 years of working to robust standards of compliance, ethics, and anti-bribery and corruption, we are positioned to make an impact by helping our clients achieve what’s next. Our global Ethics and Compliance program is led by our Chief Ethics & Compliance Officer and supported by regional compliance professionals across the globe. Ethical Policies and Practices Our Global Code of Business Conduct, published in several languages, defines the conduct expected of all officers and employees of the company. Annual online training and certification to the Global Code of Business Conduct is mandatory for all employees. The Code is updated annually, taking into account new considerations that arise during the year. We have several other policies in place that are revisited regularly and updated annually.

Global Ethics and Compliance Policies

Global Anti-Bribery & Corruption Policy Global Charitable Contributions and Sponsorships Policy Global Code of Business Conduct

Global Economic Sanctions Policy

Global Vendor/Supplier Integrity Policy

Global Conflicts of Interest Policy

Global Due Diligence Policy

Global Whistleblower Policy Global Client/Third Party Privacy &

Confidentiality Policy Insider Trading Policy Code of Business Conduct for Members of the Board of Directors Policy Concerning Related Party Transactions UK Modern Slavery Act Policy Global Workplace Privacy Policy New policy developed in 2019, issued in 2020

18 | CORPORATE SOCIAL RESPONSIBILITY REPORT 2019

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