Corporate Social Responsibility Report 2019 | Cushman & Wakefield

Our business activities are subject to a number of laws that prohibit various forms of corruption, including local laws that prohibit both commercial and governmental bribery and anti-bribery laws that have a global reach, such as the FCPA and the UK Bribery Act. Additionally, our business activities are subject to various economic and trade sanctions programs and import and export control laws, including (without limitation) the economic sanctions rules and regulations administered by the U.S. Treasury Department’s Office of Foreign Assets Control, which prohibit or restrict transactions or dealings with specified countries and territories, their governments, and in certain circumstances, their nationals, as well as with individuals and entities that are targeted by list-based sanctions programs. We maintain written policies and procedures and implement anti-corruption and anti-money laundering compliance programs, as well as programs designed to enable us to comply with applicable economic and trade sanctions programs and import and export control laws.

Through our Enterprise Risk Management Program, we maintain a systematic, disciplined approach to evaluating and improving the effectiveness of governance, internal controls and risk management processes throughout our global operations. We carry out annual Global Enterprise Risk Assessments which include corruption risk. See our 2019 Form 10-K , pp. 13 – 14 for more information on risks related to corruption. Additionally, all of our global operations are subject to internal and supplier policies that cover human rights, such as our Global Code of Business Conduct and Global Procurement Policy.

Cushman & Wakefield in Greater China completed a rigorous audit by Standard Global Services (SGS), an internationally recognized inspection, verification, testing, and certification body, and was awarded SGS’ first ISO 37001 Anti-Bribery Management Systems

Certificate in China’s real estate industry. The certificate marks the recognition of Cushman & Wakefield’s efforts to create an honest, clean and transparent business environment both internally and externally by a trustworthy third-party institution.

CORPORATE SOCIAL RESPONSIBILITY REPORT 2019 | 21