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All governance body members and employees with e-mail
addresses received e-mail communication in 2015
regarding new policies, including the Global Anti-Bribery
and Corruption Policy and the Global Code of Business
Conduct. Regions have made additional communication
efforts. In EMEA, all employees received information
regarding anti-corruption, while in APAC, anti-corruption
policy reminders were given to leaders in regular calls and
meetings, and the leaders then communicated those
policies and procedures to their employees. In Greater
China, anti-corruption policies were discussed and
emphasized in quarterly head of business meetings. In the
U.S., all new hires are required to read and certify to the
Code. Cushman & Wakefield’s Global Anti-Bribery and
Corruption Policy mandates that appropriate anti-bribery
and corruption terms and conditions be included in all new
agreements with all parties who act on Cushman &
Wakefield’s behalf. Recipients were required to
acknowledge that they had read, understood, and will
comply with the Code. In total, 35,636 global employees
received a copy of the Code, out of approximately 43,000
total. The remaining employees did not have e-mail
addresses — due to the nature of those employees’ jobs
(primarily facilities-related), they faced a very low risk of
encountering corruption, and thus were determined to
present a very low risk to the company.
In 2015, training was specifically targeted and deployed to
certain markets and employees, based on an analysis of
potential risks faced by those markets and employees.
Thus, training was mostly centered in higher-risk locations
in Asia, including China, and focused on senior leaders who
would then cascade an anti-bribery and corruption
message throughout their organization. Approximately 25
leaders in India received training on anti-corruption. In
China, all senior leaders from Legacy DTZ completed
online training. Approximately 20% of UK employees
completed in person anti-bribery training. In addition,
approximately 1% of employees in Europe and
approximately 1% in the UK completed online anti-
corruption training. In South America, anti-bribery training
was given to 29 project management employees. Anti-
corruption information was also included in Human
Resources new hire trainings conducted in APAC, South
America, and the UK.
Additional anti-corruption training, specifically tailored to
business needs, is in the works for 2016. The rollout of such
training will be determined again using a risk-based model,
with the focus remaining on higher-risk jurisdictions and
business lines. Completion of this training will be tracked
electronically. Moving forward, a specific compliance
professional will be responsible for tracking all worldwide
training, both live and on-line, and will have input to ensure
best practices are appropriately communicated.
Cushman & Wakefield defines corruption as the violation of
applicable anti-bribery laws and regulations in any
jurisdiction in which the company operates or does
business, and includes the acceptance or solicitation of a
bribe. There are no confirmed violations of the Foreign
Corrupt Practices Act, UK Bribery Act, or similar laws.
CORPORATE GOVERNANCE
Good governance ensures trust is maintained with all
stakeholders and is essential for our continued growth.
Without good governance, Cushman & Wakefield cannot
operate sustainably and create shared value with our
stakeholders. In 2015, Cushman & Wakefield established a
position of Chief Risk & Governance Officer to ensure the
highest level of governance. Along with our management
team, our Board of Directors ultimately has responsibility for
overseeing all Cushman & Wakefield business and enhancing
Cushman & Wakefield’s long-term value.
Cushman & Wakefield’s Internal Audit function identifies
opportunities to strengthen management control, improve
processes and profitability, and protect Cushman &
Wakefield’s assets and reputation. We achieve this by
bringing a systematic, disciplined approach to evaluate and
improve the effectiveness of risk management, internal
control, and governance processes by offering control
insights, observations, recommendations, internal audits,
and reviews to management, and by supporting Cushman &
Wakefield’s Risk and Audit Committee, comprised of senior
executives of the company.
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ETHICS & GOVERNANCE