Whether we realize it or not, almost all of us contribute in some way to creating CBRE's financial statements. Whether you have prepared a timesheet in France, a revenue voucher in India, an expense report in Chile or purchased goods or services in Chicago, your input is contributing to the ultimate reporting to our regulators and investors. All documents, reports or information prepared for CBRE or at the request of someone with authority are important to ensure our financial reports are accurate as required by law.

We are required to provide our stakeholders with full, accurate, timely and transparent reporting of information about CBRE. To fulfill this obligation, every business record we create or approve must be accurate, complete and reliable. We have adopted specific policies and procedures to ensure we make full, fair, accurate and timely disclosures in our periodic filings with regulators, such as the U.S. Securities and Exchange Commission and the New York Stock Exchange, and comply with our obligations under the law. We are also required to comply with the local and country-level corporations laws that govern our subsidiaries. Any failure to comply with these policies could subject the Company and its officers to significant financial liabilities and serious legal sanctions.

All of us who are called upon to provide, review or certify information in connection with any internal control or procedure must provide the most accurate, timely and complete information possible. The making or approving of false or misleading records or documentation, or the failure to properly disclose any asset or liability, undermines our ability to make good decisions and is strictly prohibited.

The result these internal controls and procedures are intended to achieve is guaranteed only if we maintain an environment of open communication, honesty and integrity throughout our entire organization— there are no short-cuts. If you have concerns (or are contacted by anyone who has concerns) about any aspect of our financial disclosures, or any accounting or audit or internal control issue, you must report them immediately to your manager, or to any of the avenues we have made available in this SOBC to report issues, including the CBRE Ethics HelpLine.

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Accuracy of Books and Records & Cooperating with Investigations Check your knowledge

A colleague asked you whether Company policy permitted hourly employees to be paid for more time than they worked. You asked your supervisor, Ken, who told you that he thought CBRE policies were "unfair" because his previous company allowed employees to record inaccurate hours as long as it all "worked out" in the end. Additionally, Ken believed that anyone who was a "hard worker" should be paid what they "deserved" regardless of actual hours worked. He felt as a supervisor it was his responsibility to "make things right."

Can Ken increase the number of hours worked on his employees timecard as a reward for their hard work?

Yes No
Correct Answer — No

It is critical that all business records, including timecards, are full, accurate, and transparent. Improperly submitting timecards could result in overbilling the customer and, in cases of service to Government customers, potentially illegal.

Jakob was arrested for driving under the influence of alcohol after being involved in an accident while driving a CBRE vehicle. Jakob disclosed the accident but not the DUI to CBRE. When specifically asked, Jakob told the CBRE employee tasked with conducting an investigation that he had not been drinking the night of the accident. Later, the investigator obtained a copy of the report from the police which documented the employee's DUI arrest the night of the accident. When confronted with the police report, Jakob could not explain the discrepancy, said he was not arrested or intoxicated, and claimed to "forget" that he had been charged with DUI.

Are Jakob's omissions in violation of the SOBC?

Yes No
Correct Answer — Yes

In order to allow our business leaders to make critical decisions, it is imperative that all employees cooperate fully and answer truthfully in the course of an internal investigation. Jakob's "omission" to the investigator could result in discipline to include termination.

Incorrect Selection

Please re-examine the situation presented carefully and choose again.

Policy Guidance
Access to Employee Records Anti-Corruption Policy
Business Records Retention and Destruction
Communications and Fair Disclosure Policy Confidentiality / Non-disclosure Conflicts Identification and Management Policy for Government Contracts Conflicts of Interest
Drug-Free Workplace
E-Marketing Policy Electronic Communication Electronic Communications & Acceptable use of Technology: Social Media Employee Assistance Program Employment of Relatives Equal Employment Opportunity
Gifts and Entertainment
Harassment-Free Workplace
Inappropriate Entertainment Information Asset Protection Internal Communications Investigations of Legal and Ethical Misconduct
Managing Conflicts of Interests - Information Barriers Media Relations
OFAC Compliance Open Bidding Outside Employment
Personal Ownership of Real Estate Political Contributions Public Relations
Report of Injuries/Accidents Restrictions on Marketing by Fax
Safe Workplace Policy Securities Compliance Smoke-Free Workplace Social Media Solicitation and Distribution Standards of Conduct
Use of CB Richard Ellis Name or Identity Use of Company Property
Violence in the Workplace