Corporate Social Responsibility Report 2016

46

ETHICS & GOVERNANCE

ETHICS & COMPLIANCE Our Chief Ethics & Compliance Officer partners with executive management and regional/service line leadership to facilitate ethical business practices, resolve impediments to our clients’ success, and reinforce the firm’s reputation by holding our employees to the highest ethical standards. GLOBAL CODE OF BUSINESS CONDUCT Our Global Code of Business Conduct (Code of Conduct), offered in eight languages, establishes the foundation for carrying out our day-to-day operations and guiding our people to make the right decisions and exhibit the right behaviors in performing these activities. All new hires are required to certify and adhere to the Code of Conduct. For 2017, we planned to require our technology-enabled employees to reaffirm their commitments to the Code of Conduct through an online certification tool. REPORTING MISCONDUCT Cushman & Wakefield employees must report all allegations of misconduct of which they become aware. Reports may be made to local management, a regional legal/compliance representative, or Human Resources business partner. Misconduct can also be reported through the Ethics Helpline. Raising questions and concerns reinforces Cushman & Wakefield’s commitment to act ethically in every business situation. Early detection of potential issues also allows Cushman & Wakefield to address concerns before they become larger problems and to take corrective action, if necessary. Above all, Cushman & Wakefield is committed to maintaining a culture where all employees are comfortable asking questions, speaking up, and working toward solutions. To that end, Cushman & Wakefield will not tolerate acts of retaliation

(including adverse impact on employment) against anyone who makes a good faith report of misconduct or who participates in an investigation of wrongdoing. ANTI-BRIBERY AND CORRUPTION Anti-bribery and corruption is material to Cushman & Wakefield because we have worked hard to build a reputation of integrity and trust. Our reputation has been instrumental in our exceptional track record and long-term success. Allegations of bribery and corruption can both negatively impact company value and pose financial, operational, and reputational risks to our investors and other stakeholders. We also understand that the business practices and actions of our suppliers reflect upon Cushman & Wakefield, its reputation, and brand. While we do not directly monitor the anti-bribery and corruption activities of our suppliers, we expect them to comply with our Global Vendor/Supplier Integrity Policy which clarifies our expectations in the areas of business integrity, labor practices, health and safety, and environmental management. For instance, the policy requires that suppliers: “ Compete fairly for the company’s business, without paying bribes, kickbacks or giving anything of value to secure and improper advantage. Cushman & Wakefield conducts business legally and ethically within the framework of the free enterprise system. Corrupt arrangements with customers, suppliers, government officials, or other third parties are strictly prohibited. ‘Corruption’ generally refers to obtaining, or attempting to obtain, a personal benefit or business advantage through improper or illegal means.” Robust anti-corruption measures and practices are necessary for an effective anti-bribery and corruption program. Our Global Anti-Bribery and Corruption Policy is translated into multiple languages and is applicable to all Cushman & Wakefield employees globally. The policy