Corporate Social Responsibility Report 2020 | Cushman & Wakefield

of our Global Anti-Bribery & Corruption Policy in business transactions. We do not authorize, tolerate or get involved in any business practice—even if it is “customary” in a particular jurisdiction—that does not comply with our Global Anti-Bribery & Corruption Policy and applicable laws. To the extent any applicable law requires standards that are stricter than the requirements of this policy, the stricter standards are followed. Our business activities are subject to a number of laws that prohibit various forms of corruption, including local laws that prohibit both commercial and governmental bribery and anti-bribery laws that have a global reach, such as the Foreign Corrupt Practices Act, the UK Bribery Act and the Australian Bribery Act. Additionally, our business activities are subject to various economic and trade sanctions programs and import and export control laws, including (without limitation) the economic sanctions rules and regulations administered by the U.S. Treasury Department’s Office of Foreign Assets Control, which prohibit or restrict transactions or dealings with specified countries and territories, their governments, and in certain circumstances, their nationals, as well as with individuals and entities that are targeted by list-based sanctions programs.

We maintain written policies and procedures and implement anti-corruption and anti-money laundering compliance programs, as well as programs designed to enable us to comply with applicable economic and trade sanctions programs and import and export control laws. In 2020, we updated our Global Anti-Bribery & Corruption Policy to reflect new gift, entertainment and hospitality limits and included a Frequency, Intent, Timing (FIT) test which allows employees to evaluate their circumstances before accepting or giving a gift. Through our Enterprise Risk Management Program, we maintain a systematic, disciplined approach to evaluating and improving the effectiveness of governance, internal controls and risk management processes throughout our global operations. We carry out annual Global Enterprise Risk Assessments which include bribery and corruption risk. See our 2020 Form 10-K, p.p. 11 – 35 for more information on risks related to corruption. Additionally, all of our global operations are subject to internal and supplier policies that cover human rights, such as our Global Code of Business Conduct and Global Vendor/Supplier Integrity Policy.

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