Many of us will have access to information of which the general public is unaware, about CBRE, our clients, business partners and competitors. Often, that information is considered “material,” meaning it would influence an individual's decision whether to buy, sell or hold the stock of that company. Examples of “material” information include corporate earnings, line of business performance, potential acquisitions, significant contract wins or losses, and lawsuits. As an employee, it makes no difference how you obtain the information. The insider trading laws in the U.S. and many other jurisdictions where we operate (e.g., the Market Abuse Directive in the U.K.) make it illegal for any of us, and our spouses, children and everyone else who lives in your home, from using material non-public information to trade in securities or tip off anyone else so that they can do so (even if you are unaware that they did). Because tipping is illegal, you should be very careful not to disclose any confidential information to anyone who does not need to know it, including close family members or friends.

Violation of these laws can have very serious repercussions for you (including large fines and even jail time) and potentially cause CBRE and its stakeholders inestimable financial damage. The Company has also adopted a Securities Trading Policy that applies to trading in CBRE's publicly listed securities, which all CBRE personnel must review and agree to be bound to.

Your Legal Department can offer guidance to keep you from violating this Standard, the Securities Trading Policy or the law, but only before you act. If you are unsure about this subject matter, you must refrain from trading or otherwise acting until you consult with the Compliance or Legal Departments and are certain that you are in compliance with our policy and the law.

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Insider Trading Check your knowledge

Sebastian was walking by a colleague's desk and noticed some papers laying face up with financial information about a publically traded client. Although the papers were clearly stamped “confidential” you could not resist the temptation to look. Sebastian dabbles in the stock market and has money invested in the client company. What he sees horrifies him – the company is planning to divest two divisions and several underutilized commercial assets and manufacturing facilities. He immediately returns to his desk and sells all the stock in the company. About two weeks later the company announces its plans, and the stock loses 70 percent of its value.

Did Sebastian do anything wrong?

Yes No
Correct Answer — Yes

Not only is this a violation of CBRE policy, but selling the stock based on insider information may result in serious criminal liability for Sebastian, to include the possibility of jail time.

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
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