Corporate Social Responsibility Report 2018

WORKING WITH INTEGRITY UPHOLDING COMPLIANCE, ETHICS AND ANTI-CORRUPTION As one of the world’s leading commercial real estate services firms, we hold ourselves to the highest standards of corporate integrity and strive to create a culture in which everyone acts out of personal accountability for protecting our business, our reputation, our commitments to our Board of Directors, our clients and all those we serve. We aim to uphold all applicable laws and regulations affecting our business around the world without exception and to uphold our own standards of ethical behavior. By protecting our industry-leading reputation, built over more than 100 years of working to robust standards of compliance, ethics and anti-bribery and corruption, we are positioned to help our clients achieve what’s next.

Our global Ethics and Compliance program is led by our Chief Ethics & Compliance Officer and supported by regional compliance professionals across the globe.

Ethical policies and practices Our Global Code of Business Conduct, published in several languages, defines the conduct expected of all officers and employees of the company. Annual online training and certification to the Global Code of Business Conduct is mandatory for all employees. The Code is updated annually, taking into account new considerations that arise during the year. In 2018, for example, minor adjustments were made to accommodate new language relating to insider trading to align our Code with expectations of Cushman & Wakefield as a newly publicly-listed company.

Maintaining robust compliance In order to provide instruction on how to conduct ourselves in an ethical manner and according to law, we maintain several global compliance policies. In 2018, we supplemented these with additional policies governing how we conduct ourselves in different trading scenarios and business relationships. Throughout the year, we engaged all relevant employees in training on these new policies, in addition to ongoing training in all areas of compliance. To monitor compliance and identify gaps, we conduct periodic audits and risk assessments of our activities and controls in targeted countries. In 2018, we created a Compliance Risk Assurance Committee with specific focus on ensuring corruption and bribery risks are identified and mitigated.

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