2022 Environmental Social Governance (ESG) Report

GOVERNANCE

ANTI-CORRUPTION AND ANTI-BRIBERY [205-1, 205-2] Cushman & Wakefield has zero tolerance for corruption, bribery or extortion. We implement relevant policies, programs and procedures to help ensure compliance across our business. Our commitment to anti-corruption and anti bribery is upheld by our Global Anti-Bribery & Corruption Policy and Global Charitable Contributions and Sponsorships Policy, which define limits on gifts, entertainment, hospitality, and political donations and lobbying. These policies are referenced in our Global Code of Business Conduct and are disseminated internally for employees. Due to the global nature of our business, we supplement the Global Anti Bribery & Corruption Policy where needed with regional/local Gift, Entertainment, and Hospitality policies based on specific local requirements or risks. These policies reflect the most updated gift, entertainment and hospitality limits set by Cushman & Wakefield and include a Frequency, Intent, Timing (FIT) test which allows employees to evaluate their circumstances and practice good judgement before accepting or giving a gift.

Our business activities are subject to regulation that prohibits various forms of corruption, including local laws that prohibit both commercial and governmental bribery and global reaching anti-bribery laws. The company’s business activities are also subject to various economic and trade sanctions and import and export control laws, for which we implement compliance training programs for employees. 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 policies or applicable laws. In cases where applicable laws or requirements are stricter than those outlined in our policies, we are committed to following the stricter standards. To further reinforce our commitment to ethical behavior, our master service agreements cover third-party vendors and require compliance with our Global Vendor/Supplier Integrity Policy, Global Code of Business Conduct and additional anti corruption policies.

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