Competing with CBRE or its clients, either personally or by aiding a competitor, is strictly prohibited. Using your contacts or position within the Company to advance our own business or financial interests in competition with CBRE or its clients is improper.

Through your position at CBRE you might become aware of an opportunity to provide a service or make an investment that could have been provided or made by CBRE itself. As employees, we owe CBRE an undivided duty to advance its business interests when the opportunity to do so arises. Accordingly, if you become aware of an opportunity that could be provided to CBRE, you must disclose it to your manager or a member of senior management so that CBRE can evaluate it. Only if CBRE has declined the opportunity (in writing) are you permitted to act on it or yourself personally (or for a family member).

In addition, the use of CBRE or client resources or vendors, suppliers or subcontractors to perform work at your personal residence, a family member's residence or for you or a family member's outside business may occur only with prior approval of the senior management in your business unit.

Because your personal ownership of certain types of real estate poses both legal and reputational ramifications to CBRE, we have established clear policies regarding employee ownership of real property and participation in aspects of the real estate markets.

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Competing with CBRE or its Clients Check your knowledge

Alex volunteers for non-profit organizations in his free time. These entities are small and do not have the budget to retain CBRE for project management services. Over several years, Alex developed an innovative new software program specifically for non-profit organizations to minimize the need for a full service project management team. Alex consults at strategic junctures with the organizations that use the software and he charges a modest fee for his services. His clientele has expanded drastically over the last 6 months and he is considering hiring project management professionals to help him grow his business.

Is this a Corporate Opportunity?

Yes No
Correct Answer — No

Provided that the services rendered by Alex are not opportunities that would be of interest to CBRE. Alex should seek written approval from his supervisor that CBRE has declined the opportunity to compete for this business.

Diana, an IT professional at CBRE, holds a brokers license. She represents buyers and sellers of residential real estate. Several years ago she informed her supervisor of her part time brokerage business and sought his approval. Since the business focused exclusively on residential properties, Dianas manager approved of the arrangement as long as it did not interfere with her responsibilities at CBRE. Much to her delight, she has recently been receiving calls from developers of mixed use properties (retail and residential) and this month she landed his first listing agreement on a large mixed use development.

Is Diana competing with CBRE?

Yes No
Correct Answer — Yes

Since the property includes retail space, Diana would be acting as a potential competitor to CBRE. Diana should have brought the opportunity to her manager before seizing the opportunity herself.

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
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Managing Conflicts of Interests - Information Barriers Media Relations
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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