In any organization with tens of thousands of employees, conflicts between personal and company interests are inevitable. So, while we cannot always avoid conflicts, we can minimize their harmful impact through the way we identify, disclose and manage them.

We know that our employees have a broad range of personal and community interests and involvement. We strive to strike the right balance between encouraging these pursuits and protecting our brand, reputation and bottom line. However, if the interests of an individual and the firm ever collide, we must always err on the side of CBRE and its clients. There is no individual whose interests are more important than the collective organization. As you make decisions on behalf of CBRE or participate in activities outside the workplace, you must be aware of our policies dealing with conflicts. Most of the time, using common sense will result in the right answer; however, it is important to know when to ask for help where you are unsure.

Conflicts of interest arise when a person representing CBRE takes an action or has a personal or family interest that has the potential to affect his or her objectivity, loyalty or work performance. Some common examples of conflicts between an employee and the firm include:

  • Outside employment;
  • Outside work for or serving on the board of directors of a client, supplier, vendor or competitor of CBRE;
  • Political or community activities that could reflect negatively on the reputation of CBRE;
  • You or a member of your immediate family owns an interest in a supplier, vendor, partner, contractor, subcontractor or competitor of CBRE; or,
  • Receiving any unusual gain, favors, gifts, kickbacks or other benefits as a result of one's position in the Company.

Even the mere appearance of a conflict can tarnish our reputation within CBRE or our reputation for fair dealing. Therefore, any action or personal interest that causes or could be reasonably expected to cause conflict of interest must be disclosed to us through stablished procedures and must have received prior approval, or else it is prohibited. When in doubt, you must disclose any factor that could even be perceived as a conflict of interest with the Legal or Compliance Departments. Remember, if you are unsure, ask before acting. In this area, making the wrong decision can have devastating consequences for you and the Company.

Employment and Other Activities Outside the Company
We encourage our employees to play active roles in their communities and in religious, environmental, charitable or other outside organizations. Many of our employees serve in leadership roles or on boards of non-profit or charitable or even political organizations. Sometimes, however, outside activities may create a conflict of interest or could cause embarrassment to CBRE. Therefore, CBRE reserves the right to prohibit service on outside organizations. Taking employment or a consulting engagement outside CBRE is permitted with the permission of your manager and only if:

  • The assignment is not with, or in aid of, a competitor or a vendor;
  • The assignment does not conflict or interfere with our CBRE job performance, responsibilities, hours or duties;
  • The assignment does not require you to use CBRE property, facilities or confidential information;
  • In any publicity relating to the activity, you do not associate the entity with CBRE without our permission; or,
  • The assignment does not require the use of the same license that is used for your CBRE employment

Serving on the board of directors of another for-profit business is permitted only with permission of CBRE, and permission may be conditioned on steps that must be taken to mitigate any real or perceived conflict of interest.

Close Friendships, and Romantic or Family Relationships
To be the strongest possible organization, we must make our business decisions based on merit and in the best interests of CBRE. Favoritism in hiring or other employment decisions that results from any factor other than performance saps our strength by demoralizing those who are most deserving.

It is a conflict of interest to supervise someone with whom you have a romantic or close family relationship. Even if you are acting impartially, other employees could perceive favoritism. As a result, the rest of the team's productivity is disrupted and morale is degraded. We recognize that we have employed family members and close personal friends of our employees. We also recognize the reality that relationships often form and blossom among co-workers. And whether they pre-existed or were recently formed, we will take steps to manage the conflicts of interest and the perception of favoritism.

We also believe that our managers are in a position of trust similar to a teacher, and that it is improper for a manager to become romantically or sexually involved with someone they supervise or who is in a subordinate position within their business unit or department. Similarly, we believe that a close friend, family member or romantic partner should not be placed in a position of direct decision-making authority (e.g., compensation) over another. If these relationships already exist, they must be disclosed so that we can take steps to protect the business and our reputation.

Learn More About:
Conflicts of Interest Between Employees and CBRE Check your knowledge

Fabiana, a site manager on an Asset Services account, fired a vendor and hired a landscaping company jointly owned by herself and her spouse without disclosing the ownership interest to CBRE or to the client. Fabiana's company charged less, and according to the client, provided superior services. Fabiana never to disclosed her (or her spouse's) ownership interests in the company because as long as the client is receiving superior services for less money, there is no conflict of interest.

Is she correct?

Yes No
Correct Answer — No

This action creates a conflict of interest because the ownership interest in the landscaping company has the potential to affect her objectivity, loyalty, and work performance. Fabiana should immediately disclose this interest to both the client and to her supervisor.

Martin, a Facilities Management manager informed potential vendors that in addition to submitting bids on various projects, he would review the quality of their work by giving them a home improvement project at his home. In this way he could learn about their work style, diligence and level of expertise. To be fair, Martin agreed to pay for all materials but because the work was part of the bidding process, no labor expenses would be covered. He believed that because he was paying for the materials and was doing it to determine the best vendors, these activities did not constitute a conflict of interest.

Is Martin's bid review proposal appropriate?

Yes No
Correct Answer — No

Through this unorthodox bid review, Martin is receiving an inappropriate benefit resulting in his position within the company. He should immediately cease the activity and notify his supervisor.

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