2021 Environmental Social Governance (ESG) Report

Communications and Training (205-2)

identified in compliance incident trends and various risk assessments. In 2021, we assigned mandatory Global Code of Business Conduct training to all employees, and mandatory Global Anti-Bribery and Corruption training was issued to select service lines that were determined to present a higher risk of bribery and corruption. The Global Anti-bribery and Corruption training covers high-risk situations and educates employees on how to successfully identify possible violations of anti-corruption laws. The training explores foundational concepts in corruption and focuses on internationally applicable anti-bribery laws and policies such as the U.S. FCPA, the UK Bribery Act and the Organization for Economic Co-operation and Development (OECD). The percentage of employees that completed mandatory training in 2021 varied across business regions and is detailed in the table below.

All Ethics and Compliance policies are distributed annually to employees by our CEO via email. Policies are also available on Cushman & Wakefield’s intranet. Global employees are assigned related trainings based on risks posed by their role, business line and geography. Additionally, our master service agreements require all third-party vendors to abide by our Global Vendor/Supplier Integrity Policy, which covers both our Global Code of Business Conduct and anti corruption policies. We reinforce our commitment to preventing bribery and corruption in our operations by training our workforce to recognize and report misconduct. Our mandatory annual trainings are determined after consideration of risk areas

2021 Mandatory Compliance Training

91.3% 98.4% 88.5% 92.4%

91.8%

87.0%

North America

South America

91.1% 93.3% 90.8% 82.2% 86.9% 76.1%

TOTAL

Greater China

APAC

EMEA

Anti-Bribery and Corruption*

Code of Business Conduct

Note: We add new hires to training on a rolling basis. This table reflects training completion for employees who received training on the initial launch dates. *Training was assigned late August 2021 and was available through April of 2022. The training completion rates here reflect completion by 2021 year-end, so final completion rates are higher.

90 | CUSHMAN & WAKEFIELD 2021 ESG REPORT