No excuse or pressure justifies breaking the law or encouraging someone else to do so. Wherever an Office has an internal policy that is stricter than what is required by local law, our employees are expected to follow that standard.
In our Offices, local laws govern almost all aspects of our business activities. Violation of such laws could subject our employees, their colleagues, their Office and CB Richard Ellis to possible fines or sanctions. All employees are encouraged to consult the UK Compliance Officer if they are unsure about a potential course of action.
Respecting the Environment
We are committed to good environmental practices. Any waste materials left over from our operations must be disposed of legally and in a way that meets the legal obligations under applicable environmental laws.
If something occurs in a facility that might be harmful to our employees or the community, we openly communicate these situations and develop a plan to correct them effectively and quickly.
We respond truthfully and responsibly to questions and concerns about our environmental actions.
Community Partnerships
We should be aware of community needs and concerns as they involve our business and clients, and work constructively with the right people and authorities to resolve issues and problems.
Political Contributions
CB Richard Ellis does not make political contributions. This applies to non-cash contributions (for example, allowing a candidate to use our facilities or resources) as well as cash contributions.
Interaction with Public Officials
There are very specific rules that govern our interactions with government officials. For example, although it might be acceptable practice in the private sector, the giving of gifts, including meals, entertainment, transport or lodging, to government officials is usually prohibited. Aside from breaking the law, it is possible that a mistake in this area would put our clients' projects and businesses (and therefore our own) at risk.
Breaking government rules, whether or not intentional, could result in serious consequences. Employees with any questions are advised to seek guidance from the UK Compliance Officer.
Dealing with Foreign Government Officials
Our employees and agents must comply with anti-bribery statutes, including the Foreign Corrupt Practices Act (the "Policy"). These provisions prohibit individuals and companies from making payments, promises or offers of anything of value to foreign government officials to obtain or retain business or to secure an improper advantage. The prohibition extends to doing these things indirectly through third-parties while knowing that the third party will make the prohibited payments.
Certain types of payments are not prohibited, if legal in the official's country and if the payment is related to a legitimate business purpose. More guidance on the types of payments that are prohibited or permitted is included in the Policy and is available from the UK Compliance Officer.
To minimize exposure to potential liability from unauthorized actions of agents working on our behalf, we have adopted carefully designed procedures for selecting and appointing our representatives and requirements for standard provisions are included in our contracts with them. These are also set forth in the Policy. In addition, because of the risk involved in this area and the difficulty in identifying whether a payment is legal, all payments to foreign government officials must be approved in advance by the UK Managing Director and the EMEA Chairman.
