2022 Environmental Social Governance (ESG) Report

COMMUNICATIONS AND TRAINING [205-2] At Cushman & Wakefield, we take a proactive approach to promoting ethical behavior and preventing bribery and corruption in all aspects of our business. To help ensure that our employees are well-informed of our Ethics and Compliance policies, they are distributed annually via email from our CEO, and they are available on our company intranet in 20 languages. Employees are assigned training based on their role, business line and geographic location to help ensure that they are equipped to recognize and mitigate risks associated with their position. In order to ensure compliance with our Code of Business Conduct, we mandate annual online training and certification to the Code for all tech enabled employees. Our Code of Business Conduct training specifically covers anti-bribery and anti corruption risks to empower employees to identify possible violations of applicable anti-bribery and anti-corruption laws such as the U.S. Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act. Regions provide supplemental trainings and communications as needed based on relevant risks or specific issues.

In 2022, we introduced a mandatory Global Conflict of Interest training to provide guidance on recognizing and avoiding conflicts of interest in the workplace. The Conflict of Interest training was designed to ensure that employees avoid activities or relationships that may impair, or appear to impair, their ability to make objective and fair business decisions when performing business duties. When such conflicts arise, employees must immediately report them to their manager, a member of our People Team, or a company legal or compliance representative. The effective identification and management of conflicts of interest are essential to maintain our reputation for professional integrity and manage commercial risks associated with acting as a professional advisor to clients. To help ensure that our training programs are effective, we track and report on the percentage of employees who have completed mandatory training in a given year. We believe that our training programs play a critical role in fostering a culture of ethics and compliance throughout our organization.

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