2023 Sustainability Report

INTRODUCTION OUR CLIENTS OUR PLANET OUR PEOPLE AND COMMUNITIES OUR BUSINESS ACKNOWLEDGEMENTS ABOUT THIS REPORT APPENDICES

2023 SUSTAINABILITY REPORT | 70

Our Approach

Ethics and Compliance

Supply Chain Management

Governance

Data Privacy and Security Stories of Progress

Ethics and Compliance

Reporting Misconduct Within the enhancements we are bringing to our Ethics & Compliance program, an area of focus is reporting and investigating misconduct. We are working to ensure that there is rigor to the investigation process, and to ensure that employees are confident that if they report misconduct, the information will be handled confidentially, incidents will be investigated thoroughly and in a timely manner, and there will be no retaliation. We seek to encourage a culture in which our employees understand the importance of speaking up . > The new internal investigation policy, established in 2024, outlines notification — or what matters will be escalated to whom — and how disciplinary decisions will be made. > We are developing a communication plan for broadcasting these changes across the organization with a focus on encouraging employees to raise issues. LIST OF CUSHMAN & WAKEFIELD’S ETHICS AND COMPLIANCE-RELATED POLICIES > Global Code of Business Conduct > Environment Policy > Global Vendor/Supplier Integrity Policy > Vendor Code of Business Conduct Commitment > Global Anti-Harassment and Anti-Discrimination Policy > Global Whistleblower Information

Code of Conduct Training Our Global Code of Business Conduct, published in 20 languages, defines the ethical conduct expected of all directors, officers, partners, employees, temporary employees hired through agencies, brokerage professionals and independent contractors (as defined in the Code). We mandate annual online training and certification to the Code for all in-scope employees. We expect to launch a new Code of Conduct course in mid-2024, highlighting risk areas for the industry. The course will address issues that are tailored to Cushman & Wakefield’s operating environments, and the kinds of issues that are more likely to arise for our employees in the course of their work. We will continue to carry out our Annual Ethics Week and communicate with employees throughout the year regarding relevant ethics and compliance issues.

At Cushman & Wakefield, we recognize the crucial role our employees play in upholding our integrity and conducting business with high ethical standards. Our company culture emphasizes personal accountability, aiming to ensure that we all prioritize the protection of our business, colleagues, clients and the communities we serve. We are actively working to reinforce our culture of “doing the right thing” and emphasizing a more principled approach to our ethics and compliance program. Our global Ethics and Compliance program is led by our Chief Ethics & Compliance Officer (CECO), who is supported by the Vice President & Global Compliance Counsel, regional compliance directors, Head of Global Investigations and the Global Privacy Lead. The CECO provides quarterly compliance updates to the Audit Committee on the Ethics & Compliance program and investigations. Ethics and compliance risks are identified through a variety of methods: Enterprise Risk Management, Internal Audit, ethics and compliance investigations, third-party due diligence, risk assessments, business advisory functions and meetings with senior leadership. We have continued to enhance how we approach ethics and compliance risk and third-party risk assessment to ensure that we are taking a holistic and risk-based approach. Our employees are also expected to act in accordance with our Global Anti-Harassment and Anti-Discrimination policy (which includes our Anti-Retaliation policy), and our Global Whistleblower policy, and adhere to all laws and regulations to which our global operations are subject.

In 2023, 93.8% of Cushman & Wakefield employees completed Code of Conduct Training.