Our business dealings on behalf of our clients put us in direct contact with local, state and federal government officials. And while we strive to maintain good relationships, 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 exchanging of gifts—including meals, entertainment, transportation or lodging—with government officials is often strictly prohibited. Aside from violating the law, it is possible that a misstep in this area would put our clients' projects and businesses (and therefore our own) at risk.
Regardless of the market in which we operate, clients choose CBRE not only for our outstanding service, but because of our reputation for fair and ethical business dealings. While this reputation has been built over a century of hard work by thousands of employees, it can be harmed by just one employee offering a bribe or kickback in any form. Aside from damaging our reputation, corruption allegations can lead to costly and disruptive government investigations, large fines and criminal penalties against CBRE and the individuals involved.
We have adopted a Global Anticorruption Policy prohibiting the offering or paying of bribes by any employee or agent of the Company. This prohibition extends to payments to both government entities and commercial ones. No manager can override this prohibition or any other provision of the Policy. The prohibition extends to doing these things indirectly through third parties while knowing that the third party will make the prohibited payments. Additional guidance on the types of payments that are prohibited or permitted is included in the Policy and available from your Legal Department. To minimize the exposure to potential liability from unauthorized actions of representatives working on our behalf, we have adopted carefully designed procedures for selecting, vetting and managing our business partners who interact with government officials on our behalf and requirements for standard provisions in our contracts with them. The Policy also sets forth the requirement that we maintain accurate books and records so that no questionable transaction can possibly be obscured and parameters for the strong financial controls necessary to comply with our obligations under the anticorruption laws. Each of our operations has adopted policies regarding gifts, travel, entertainment and hiring that are consistent with our global anticorruption compliance program.
Each individual at all levels of the Company has the personal responsibility to resist participation in any form of corruption and to report violations. Violating these rules, whether or not intentional, could result in serious consequences for you and CBRE. You should always seek guidance from the Legal or Compliance Departments if you have any questions.