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.

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Dealing with Government Entities; Anticorruption Check your knowledge

Business is good for CBRE in the country of Centralia. Revenue has grown by 20% this year, and as the country's Managing Director, you believe it is time to hire another manager. After a long recruitment process, you have selected an outstanding candidate and file the necessary state paperwork. Upon receipt of your perfectly completed documentation, local officials tell you that it may take weeks to approve the work permit unless a "surcharge" is paid, in cash. You quickly realize that the local official is asking for a bribe.

Do you pay local official?

Yes No
Correct Answer — No

Refuse to pay, explaining that CBRE does not allow payment of such "surcharges" to obtain work permits, regardless of the amount, unless expressly required by law. Immediately notify your Manager or the Legal Department.

CBRE is bidding for a large facility management contract for several government buildings. One of the members of the CBRE capture team, Darius, is approached by a former senior government official, Ryland. Ryland tells Darius that if CBRE will hire him as a consultant, he can "guarantee" a contract win. Darius inquires further, and Ryland tells him that for double the rate of a normal fee, he can have "extra" influence with the government officials in charge of awarding the contract.

Should Darius be concerned that Ryland's offer is too good to be true?

Yes No
Correct Answer — Yes

The fact that Ryland is asking for twice the normal fee creates a "red flag" situation where he may be using part of his compensation to bribe government officials. Before hiring Ryland, Darius should contact his Management and the Legal or Compliance Departments.

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