2021 Environmental Social Governance (ESG) Report

Reporting Misconduct Our employees play an integral role in creating an ethical and socially responsible culture at Cushman & Wakefield. Therefore, we aim to empower employees to speak up to address potential breaches of compliance or unethical conduct. We urge employees to report concerns and do not tolerate acts of retaliation against those who do so. Confidential reports can be made to local management, a regional legal or compliance officer, managers in our People Function, or through our global, 24/7, multilingual hotline administered by EthicsPoint. Reports may be made anonymously. All reports are investigated promptly, thoroughly and consistently with applicable laws. Anti-Corruption (205-103, 205-2) Cushman & Wakefield has zero tolerance for corruption, bribery or extortion. Our 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. Additionally, our commitment to ethical business practices is upheld by incorporating the principles of our Global Anti-Bribery & Corruption Policy in business transactions. We do not authorize, tolerate or participate 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. In 2021, we created Regional/Local Gifts Entertainment, and Hospitality Policies to set stricter requirements than the Global Anti-Bribery & Corruption Policy where necessary. 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 U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act and the Australian 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. In 2021, we updated our Global Anti-Bribery & Corruption Policy to reflect new gift, entertainment and hospitality limits and included a Frequency, Intent, Timing (FIT) test which allows employees to evaluate their circumstances before accepting or giving a gift. 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 evaluate bribery and corruption risk. See our 2021 Form 10-K for more information on risks, including those related to corruption. Additionally, all global operations are subject to internal and supplier policies that cover human rights, such as our Global Code of Business Conduct and Global Vendor/Supplier Integrity Policy.

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