CBRE competes in markets and business lines all around the world. We compete solely on the merits of our services, the prices we charge and the client loyalty we earn from a job well done. Our RISE values require that we support free competition and compete fairly and ethically and in a manner consistent with the laws of each country in which we do business. The laws relating to competition (e.g., antitrust) are complex and violations carry severe penalties, including fines and jail time for individual employees. Thus, all of us must ensure that our conduct is consistent with our values and the laws. A few helpful tips for compliance in this area follow:

  • Avoid any discussions with competitors regarding pricing of services unless the discussions have an appropriate business purpose and then, keep the discussions to a minimum.
  • Do not enter into any agreement with a competitor except as approved by the Legal or Compliance Departments (e.g., co-brokerage or data sharing).
  • Certain types of agreements with competitors are always illegal and must be avoided regardless of the circumstances (e.g., agreeing with competitors on prices we or they will charge, standing down or colluding on a competitive bid, or dividing territories or clients). If a conversation with a competitor enters an inappropriate area, end the conversation at once and report it to the Legal Department or Compliance.
  • Always be truthful about our competition's services.
  • Avoid any action that could be alleged to be an illegal interference with a competitor's contractual relationship with a third party (e.g., its client). If you are unsure of the right decision to make, please seek the advice of the Legal or Compliance Departments
Learn More About:
Fair Competition Check your knowledge

Heidi, a current CBRE employee, has lunch with her former boss, Paulo, a senior investment properties banker from a competing company. While most of the conversation is about the weather and family, Paulo suddenly changes the subject and says to Heidi: "I know that CBRE is our only competition for the listings at 85 King Street and 316 Queen Avenue. If CBRE ‘no bids' King Street, we will withdraw from the bidding on Queen Avenue. It's a win-win for both of our companies."

What should Heidi do?

A) Take the deal. Everyone wins in the end. B) End the conversation and leave the bar. Heidi should then immediately report the conversation to either her Manager, Legal, or the Chief Compliance Officer.
Correct Answer — B

It is always unlawful to divide markets, allocate customers, or rig bids. Because of the gravity of Paulo's solicitation, it is important to notify your manager, legal, or the Chief Compliance Officer to protect you and CBRE from such improper activity.

Same scenario as before, and Heidi accepts Paulo's offer. However, Heidi advises Paulo not to put this agreement in writing. Paulo withdraws from the bidding on Queen Avenue and Heidi's team ‘no bids' King Street.

Is this okay since the agreement was informal and not in writing?

Yes No
Correct Answer — No

The legal and reputational risk to Heidi and to CBRE is the same regardless of whether the agreement was written or verbal. CBRE complies fully with all laws regulating commercial practices, and Heidi actions would subject her to serious repercussions, both within the company and by law enforcement.

Incorrect Selection

Please re-examine the situation presented carefully and choose again.

 
Policy Guidance
×
A
Access to Employee Records Anti-Corruption Policy
B
Business Records Retention and Destruction
C
Communications and Fair Disclosure Policy Confidentiality / Non-disclosure Conflicts Identification and Management Policy for Government Contracts Conflicts of Interest
D
Drug-Free Workplace
E
E-Marketing Policy Electronic Communication Electronic Communications & Acceptable use of Technology: Social Media Employee Assistance Program Employment of Relatives Equal Employment Opportunity
G
Gifts and Entertainment
H
Harassment-Free Workplace
I
Inappropriate Entertainment Information Asset Protection Internal Communications Investigations of Legal and Ethical Misconduct
M
Managing Conflicts of Interests - Information Barriers Media Relations
N
Non-Retaliation
O
OFAC Compliance Open Bidding Outside Employment
P
Personal Ownership of Real Estate Political Contributions Public Relations
R
Report of Injuries/Accidents Restrictions on Marketing by Fax
S
Safe Workplace Policy Securities Compliance Smoke-Free Workplace Social Media Solicitation and Distribution Standards of Conduct
T
Timekeeping
U
Use of CB Richard Ellis Name or Identity Use of Company Property
V
Violence in the Workplace