CBRE is committed to conducting business with integrity and in compliance with the letter and spirit of the law. We operate in a world where laws and other standards that govern business conduct are more complex and demanding than ever.
We recognise that breaking them could have very serious consequences for ourselves and our employees.
The Standards of Business Conduct (“the Standards”) reflect the fundamental principles that govern our ethical and legal obligations. It describes, summarises and supplements policies, some of which have been in place for years.
We have organised the Standards into four categories:
Working with business partners, clients and competitors
Ethics in our Workplace
Our Resources and Information
Working in the community
What they don’t cover
No policy manual, however detailed, can anticipate all of the situations and challenges faced at work. The Standards are not intended to be an exhaustive description of policies or the law. In the UK we operate in accordance with our Business Management Systems Manual (“BMS Manual”) and, where relevant, the RICS Rules of Conduct (“RICS Rules”). Our staff are required to abide by our Employee Handbook (“Handbook”).
Global Standards
The Standards apply to personnel, board members and other people acting on the company’s behalf. Everyone at CBRE has a responsibility to understand and practice these policies. Anyone who engages vendors, consultants or temporaries is responsible for monitoring their work to ensure they act in a manner consistent with the Standards.
CBRE is a global company so rules governing conduct will vary from region to region.
But, there are certain principles that apply globally. The obligation to act with unwavering integrity does not end once you cross a border. The Standards have been customised, translated and implemented in each of our EMEA Offices.
The Employee Commitment
Every CBRE employee is responsible for their own business conduct. The Standards represent an absolute commitment to doing the right thing. By being part of CBRE employees make a commitment to knowing and following the laws that apply to their job. If they fail to follow the Standards, they put themselves, their Office and CBRE at risk. They also risk disciplinary action that could culminate in dismissal or legal action.
Knowing when and how to speak up and raise questions is of vital importance.
That is why, in addition to knowing the legal and ethical responsibilities that apply to their job, employees should speak up if:
They are unsure about the proper course of action and need advice
They believe that someone acting on our behalf is doing may be about to do – something that violates the Standards or the law; or
They believe they may have been involved in any misconduct.
Ethics and Compliance Programme
The Standards are the centrepiece of a global CBRE initiative called the Ethics and Compliance Programme. The Programme was adopted by our US Board of Directors on September 20, 2004 and the Board maintains active oversight over its implementation and operation. The Programme is administered by CBRE’s Chief Compliance Officer in the US, currently the General Counsel. The Chief Compliance Officer will make regular reports to the US Board of Directors regarding the implementation and effectiveness of the Programme. The Chief Compliance Officer will be advised by the Ethics and Compliance Committee, comprised of senior officers and other personnel involved in relevant areas at each of our business units around the world.
The Chief Compliance Officer also establishes the standards for the Ethics and Compliance Programmes that will be implemented in each Country and region in which we operate worldwide. In each case, the Programme includes:-
An ongoing training and communication programme to set the right tone and reinforce the Standards;
Implementation of a confidential means of asking questions, raising concerns or reporting violations of legal compliance or business ethics policies, including a no-tolerance policy against retaliation;
Communication of how investigations of, and discipline for breaches of the Standards will be handled; and
Ongoing initiatives to measure our progress and to constantly improve.
United Kingdom
