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.

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Exchanging Gifts and Entertainment Check your knowledge

Your supervisor, Doris, attended an event over the weekend and came into the office Monday morning all abuzz with excitement about a potential opportunity to land a huge Government contract with the US Department of Agriculture. She mentioned that at dinner on Saturday night she sat next to the procurement officer who will be a key decision-maker on the contract award. Then, Doris asked you to go online and buy a specific bottle of French wine and make sure it is shipped directly to the procurement officer. Your supervisor gives you her personal credit card to pay for the wine, which is about $60USD.

Is this appropriate in this situation?

Yes No
Correct Answer — No

While in the commercial world this gift may be appropriate, Government officials have their own set of ethical guidelines regarding accepting gifts and entertainment. Seek advice from Legal or Compliance before providing a gift or business gratuity to any government official.

A broker, Shana, offers to take an important client out to a nice dinner. During the meal, Shana and the client discuss the possibility of leasing space in a newly renovated office park. The meal consists of five courses, including desert, and they share a bottle of wine. Shana pays for the entire dinner.

Was it appropriate for Shana to do so?

Yes No
Correct Answer — Yes

Provided that the dinner was not excessive or offered with the intent to influence a business decision, we do not prohibit reasonable expenditures for meals with a bona fide business purpose.

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