Exchanging business gifts and entertainment is a customary practice throughout most of the world and promotes good working relationships and goodwill among vendors, clients and business partners. For example, we recognize that it is customary and routine (indeed, often expected) for real estate sales professionals to sponsor events and to entertain clients or provide gifts in certain circumstances. CBRE recognizes that gift-giving is synonymous with the holiday season and even an expected part of doing business that time of year. In fact, many of our offices will be filled with mail-order fruit baskets, candy and other gifts sent from vendors, clients and others during the holiday season.
We do not prohibit reasonable expenditures for travel, meals, entertainment, client events and gifts and similar or related expenses with a bona fide and documented business purpose. However, gifts and entertainment, if excessive, could cause real or perceived conflicts of interest or at worst could be alleged to be bribes or kickbacks. There is a line between these customary gifts and the types of gifts or entertainment that are perceived to be excessive.
Giving or receiving gifts is not appropriate if it creates an obligation, puts the giver or receiver in a situation where either appears to be biased or is done with the intent to influence a business decision. For example, gifts that are excessive or accepted under certain questionable circumstances (e.g., from opposing parties in a deal or from a party with whom you are negotiating a contract) could create a conflict of interest or the perception of one. At worst, an excessive gift could be considered a form of commercial bribery, and therefore gifts cannot be given to anyone to help CBRE acquire or retain business or to encourage that person to do something corrupt, deceitful or otherwise opposed to the person's responsibilities.
Therefore, each country operation, region and business has adopted policies, approved by the Compliance Department, governing expenditures for travel, meals, gifts and entertainment. These policies are designed to comply with all applicable laws and regulations relating to those operations—while always fostering our RISE value of Integrity.
Please review our Gift and Entertainment Policy and our Anti-corruption Policy for more guidance.
Regarding giving gifts or entertaining clients on behalf of CBRE, a few simple principles apply:
- We believe that we offer the best services in the industry—any business that has to be won by providing unusual or excessive gifts or hospitality is business we do not need.
- We must be aware of, and respect, our clients' own policies in these areas. Ask your client in advance about its policy on accepting gifts and entertainment.
- We also must be sure that all expenditures have been appropriately authorized and are correctly recorded on our books.
- Gifts of cash and cash equivalents (i.e., anything readily exchanged for cash such as gift cards, vouchers, etc.) are prohibited.
Our policies also acknowledge that stricter and more specific rules and policies apply when we do business with any government entity, agency or agent. The laws of many countries prohibit the giving of anything of value to a government employee. And our global Anticorruption Policy contains strict prohibitions on providing anything that could be perceived as a bribe to gain or maintain any business advantage. Because of the sensitive nature of these relationships and the complexity of the laws in this area, we should always review the applicable policy and seek advice from the Legal or Compliance Departments before offering any gifts or hospitality to government employees.
Regarding the receipt of gifts and entertainment, no CBRE employee is authorized to accept any gift that could be perceived to improperly influence CBRE's business or purchasing decisions or any decisions on behalf of any client. If you are offered a gift that is inappropriate, politely decline. If refusing the gift would embarrass or hurt the person offering it, you may accept it on behalf of CBRE and then immediately report it to a member of senior management and follow instructions regarding how to deal with the gift. If you are unsure about whether you can accept a particular gift or invitation, ask your manager or someone in Compliance or the Legal Departments for guidance. If you are not able to ask, you should politely decline the offer.