42 / 54
ETHICS AND COMPLIANCE
Cushman & Wakefield and all of the firms that come
together under this iconic brand have worked hard to build
and maintain a reputation for integrity and trust. Those
qualities have been a driving force behind our approach to
all aspects of our business, from putting our clients’
interests first in all that we do, to aligning with and acquiring
like-minded firms in major markets worldwide that share the
same high standards of conduct.
ETHICS AND COMPLIANCE INFRASTRUCTURE
Cushman & Wakefield is committed to achieving and
maintaining the highest standards of ethical conduct and
institutional integrity, and complying with all laws and
regulations, accounting standards, and ethical guidelines. To
support these efforts, we established a formal Ethics and
Compliance Program, led by the Chief Ethics and
Compliance Officer. Cushman & Wakefield recently
deepened its commitment by increasing the number of
professionals in the program and appointed Regional
Compliance Officers in all major operating regions who
report to the Chief Ethics and Compliance Officer.
ETHICS AND COMPLIANCE POLICIES
The Global Code of Business Conduct communicates our
values to employees, and the company expects that its
suppliers, agents, business partners, and consultants will
follow similar principles. The principles set forth in the Code
provide both a foundation for day-to-day operations and a
guide to employees on the right decisions and behaviors in
performing daily activities. The Global Code of Business
Conduct details the following:
1. Respect for individuals
2. Privacy and confidentiality
3. Conflicts of interest
4. Compliance with laws, rules, and regulations
5. Gifts, entertainment, hospitality, political donations,
charitable donations, and sponsorship
6. Protection and proper use of company assets
7. Use of social media both in a personal and professional
capacity
8. Accurate books and record keeping
9. Communications systems
10. Records retention
11. Asking questions and reporting
Cushman & Wakefield further regulates ethical business
practices through our internal policies, which are available in
multiple languages. Enforcement of these policies is
supported by internal audits and regular employee training.
Our policies complement the overarching Global Code of
Business Conduct and include:
• Global Anti-Bribery and Corruption Policy
• Global Conflicts of Interest Policy
• Global Due Diligence Policy
• Global Economic Sanctions Policy
• Global Vendor Supplier Integrity Policy
• Global Whistleblower Policy
To help enforce our Code of Conduct, Cushman & Wakefield
created the Ethics Help Line, administered by EthicsPoint,
an external provider. The Help Line allows individuals to
report concerns, including any potential misconduct,
unethical behavior, or violation of company policy or law,
through a hotline or web portal. Cushman & Wakefield
encourages employees to speak up and raise questions, and
the Ethics Helpline allows them to bring attention to their
concerns, which may be reported anonymously if they so
choose. Employees are advised to provide as detailed
information as possible, to better allow for a thorough and
objective investigation.
COMMUNICATIONS AND TRAINING
As part of its day-to-day operations via the resources of
compliance staff around the world, the Ethics and
Compliance program continually, and on an ongoing basis,
assesses corruption risks faced by Cushman & Wakefield. In
addition, legacy DTZ engaged an external consultant in 2015
to conduct a review of corruption risks faced by the
company and provide recommendations for continued
improvement. This high-level review, with the intent of
strengthening process controls, assessed risks globally and
throughout the organization.
42
ETHICS & GOVERNANCE