Cushman & Wakefield Corporate Social Responsibility Report 2018

GLOBAL ETHICS AND COMPLIANCE POLICIES IN PLACE AT CUSHMAN & WAKEFIELD

NEW POLICIES ADDED IN 2018

>> Code of Business Conduct >> Anti-Bribery and Corruption Policy >> Economic Sanctions Policy >> Vendor/Supplier Integrity Policy >> Conflicts of Interest Policy >> Due Diligence Policy >> Whistleblower Policy >> Client Third Party Privacy Confidentiality Policy

>> Charitable Contributions and Sponsorships Policy >> Insider Trading Policy >> Global Code of Business Conduct for Members of the Board of Directors >> Policy Concerning Related Third-Party Transactions

“As Cushman &Wakefield continues to grow, one of our top priorities is continuing to ensure that ethical and legal business practices are instilled in our operations across the firm. Since becoming a public company, we’ve put in place additional policies and standards into our existing ethics and compliance framework to meet the demands of our stakeholders, and to continue to protect our people, clients, shareholders and reputation as a leader in the industry.” Maria D’Avanzo Chief Ethics and Compliance Officer

Reporting misconduct We encourage a culture where employees are empowered to speak up to address potential breaches of compliance or expected ethical conduct. We urge employees to report concerns and do not tolerate acts of retaliation against those who do. Confidential reports can be made to local management, a regional legal or compliance officer, human resources managers or through our global 24/7 multilingual Ethics Hotline.

Enhancing data privacy In 2018, we appointed a General Data

Protection Regulation (GDPR) Project Manager in our EMEA region business region and rolled out comprehensive training for all relevant business teams. To further enhance our existing structure and systems to maintain data privacy, we hired a new Data Privacy Manager in early 2019.

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