Corporate Social Responsibility Report 2019 | Cushman & Wakefield

Communications and Training In 2019, we increased employee engagement through communications related to our Global Compliance Portal, a one-stop-shop for compliance resources, and Charitable Giving Tool, an internal online platform through which all charitable contributions and charity-related sponsorships must be requested and approved. These compliance platforms increase the visibility of each employee’s responsibilities as a corporate citizen. Our mandatory annual trainings are determined after consideration of risk areas identified in compliance incident trends and various risk assessments. In 2019, we launched the following mandatory trainings:

Protecting Personal Information In 2019, we continued our risk-based approach in protecting the personal information we hold on behalf of our company, third parties and employees. We hired an EMEA Privacy Lead to oversee and enhance our General Data Protection Regulation (GDPR) program. In addition, we kept an ear to the ground on the development of California Consumer Privacy Act regulations to ensure our practices are compliant and in- line with industry standards. We also created a Global Workplace Privacy Policy, which describes the ways we handle and protect the personal information of our staff members. Cushman & Wakefield has zero-tolerance for corruption, bribery or extortion. Our new Global Charitable Contributions and Sponsorships Policy outlines our approach to being a good corporate citizen; we never offer or accept gifts, payments or hospitality to encourage or reward a decision. The policy is a key part of our Anti- Bribery & Corruption Program. Additionally, our commitment to ethical business practices is upheld by incorporating the principles of our Global Anti- Bribery & Corruption Policy in everyday business transactions. We do not authorize, tolerate or get involved in any business practice – even if it is “customary” in a particular jurisdiction – that does not comply with our Global Anti-Bribery & Corruption Policy and applicable laws. To the extent any applicable law requires standards that are stricter than the requirements of this policy, the stricter standards are followed. Anti-Corruption (205-103, 205-1, 412-1)

• Code of Conduct

• Global Conflicts of Interest

• Business Courtesies

• Anti-Corruption & Foreign Corrupt Practices Act (FCPA): Focus on Red Flags, Third Parties and Due Diligence

Reporting Misconduct We encourage a culture where employees are empowered to speak up to address potential breaches of compliance or expected ethical conduct. We urge employees to report concerns and do not tolerate acts of retaliation against those who do. Confidential reports can be made to local management, a regional legal or compliance officer, human resources managers or through our global 24/7 multilingual Ethics Hotline.

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