CBRE is firmly committed to conducting business with the highest integrity and in compliance with the letter and spirit of the law. We are operating in a world where the rules that govern business conduct are more complex and demanding than ever. Violating them could have very serious consequences to CBRE and you.
RISE: Respect, Integrity, Service, and Excellence. It's pretty amazing how just four words can say so much. But that is the power of values. They don't have to be complicated. They don't even need to be unique. They only need to be true. Our corporate values are the foundation upon which our company is built. These values are timeless and transcend all markets, service lines, languages and business cultures.
- To treat everyone with dignity, value their contributions, and help one another succeed.
- To uphold the highest standards of truthfulness and reliability in our business practices.
- To dedicate ourselves to making a meaningful impact with our clients and in our communities.
- To aspire to be the best in everything we do and drive for continuous improvement.
Maintaining a culture where our RISE values are acknowledged and adopted universally is the cornerstone of our business philosophy. Our leaders around the globe know that implementing these values consistently in 60 countries globally is a challenge, especially when viewed through the lens of local cultures and business practices. Conduct that appears appropriate from one culture's perspective might be perceived differently from another's. However, through good economic times as well as bad, the surest path to leadership and growth is remaining true to our RISE values. Each of us needs to believe in these values. They should guide all of our actions and interactions, every day. Our future success will be determined in no small part by the commitment we make to living these values.
What is the SOBC?
The SOBC is an expression of our RISE values and represents a framework for decision-making. To this end, our employees are responsible for understanding the SOBC and acting in accordance with it. The SOBC cannot and is not intended to cover every applicable law, rule or regulation or provide answers to all questions that may arise. For that, we must ultimately rely on each employee's good sense of what's right, including a sense of when it is proper to seek guidance from others with respect to the proper course of conduct. The SOBC does not in any way constitute an employment contract or assurance of continued employment. It is for the sole and exclusive benefit of CBRE and may not be used or relied upon by any other party. CBRE may modify or repeal the provisions of the SOBC or adopt a new SOBC at any time it deems appropriate, with or without notice.
The SOBC embodies the fundamental principles that govern our ethical and legal obligations. They describe, summarize and implement policies, some of which have been in place at CBRE for many years. We have organized the SOBC into four general categories that encapsulate how we accomplish our activities on a daily basis:
- Conduct Relating to Each Other
- Conduct Relating to Our Business Partners, Clients and Competitors
- Conduct Relating to CBRE's Resources
- Conduct Relating to Our Communities
Within each of the four categories, you will find policy sections. Within each section, you will find text explanations and resources for seeking further information, including Company policies applicable to that section, either globally applicable or specific to your location. Where a policy covers a topic within this guide, we have provided a live link. In each section we have also provided easy-to-use Learning Aids and a place for you to provide us feedback. We created the Learning Aids based on real-world situations involving the policies or questions that our employees have asked regarding these policies. We hope these Learning Aids will be helpful in making the SOBC and the topics within “come to life.” Throughout the online format, you will also find important contacts and an explanation of avenues for reporting concerns or asking questions.
What it's Not
No standards of conduct, however detailed, can possibly anticipate all of the situations or challenges we might face on the job. The SOBC serves as a roadmap and is not intended to be an exhaustive description of CBRE's policies or the law. In addition to these standards, all employees are subject to other CBRE policies that, depending on your position or location, are incorporated into your terms or contract of employment or our employee handbook or manual.
If your questions are not fully addressed by these resources, your next step should be to discuss it with your supervisor or manager. Other resources are also available—including professionals in the Legal, Compliance, Finance and Human Resources Departments and the CBRE Ethics HelpLine.
Application to All of Us, Worldwide
The SOBC applies to our personnel, board members and other people acting on our behalf. Each of us has a personal responsibility to understand these policies and practice them in our daily business lives.
As a global company, we recognize that the specific rules governing our conduct will vary from region-to-region and country-to-country. However, our RISE values transcend these variances and apply to all of us globally. For example, the obligation to respect our colleagues or to act with unwavering integrity does not end once you cross a national border. The SOBC has been designed to be as “globally inclusive” as practicable, and it has been customized, translated and implemented in each country in which we operate. The business units and regions may, however, adopt policies and procedures that are more specific or restrictive than those contained within the SOBC. If there is a conflict between a local law or regulation and the SOBC, the local law or regulation would take precedence.
Anyone who engages vendors, consultants or temporaries on our behalf is responsible for monitoring such persons' work to ensure they act in a manner consistent with the SOBC. If you need guidance in this area, you should contact your supervisor or manager, or a member of the Legal, Compliance or Human Resources Departments.
Your Personal Commitment to Do the Right Thing
Each person at CBRE is responsible for his or her own conduct. The SOBC represents a non-negotiable commitment to “do the right thing” when acting on behalf of CBRE. By being part of CBRE, you are making a personal commitment to understand the policies and laws that apply to your job—and to always follow them. We reinforce this commitment annually through mandatory employee certifications. If you have joined CBRE, made this commitment and fail to keep it, you put yourself, your co-workers and CBRE at risk. You will be subject to disciplinary action, up to and including termination, and possibly legal consequences.
Additionally, we cannot live up to these standards if we, as individuals, fail to raise concerns when we should. That is why, in addition to knowing the legal and ethical requirements that apply to your job, it is part of your responsibilities to bring issues forward if:
- You are unsure about the proper course of action and need advice;
- You believe that someone acting on behalf of CBRE is doing—or may be about to do—something that violates our values or the law; or,
- You believe you may have been involved in any misconduct.
Special Responsibility of Managers
If you are a manager, you have special trust and responsibilities under the SOBC. Our managers have a great deal of influence over CBRE's values and culture. Managers are expected to embody our RISE values, set an example with their own conduct and act promptly when they become aware of something that violates the SOBC, other policies or law.
Who Should I Contact for Help?
If you have a question or concern about an ethical or compliance-related issue, you have multiple options. Your supervisor or manager is usually a good place to start. You may also get help and advice from:
- Any member of your management team;
- Any member of the Human Resources, Compliance,or Legal Departments;
- The Chief Compliance Officer – ChiefCompliance@cbre.com; or,
- The CBRE HelpLine – (800) 799-6523 (see next section)
Your business unit or region may establish additional avenues of reporting issues or concerns. The most important thing is that you raise the concern quickly and effectively.
The CBRE Ethics Helpline
We have provided a confidential and anonymous method for you to ask questions and raise concerns about our SOBC—the CBRE HelpLine. The CBRE HelpLine is always available if you are uncomfortable using one of the other resources identified in the SOBC, or if you are not satisfied with the response you have received from them.
The CBRE HelpLine is operated 24/7 by an independent company. When you call the CBRE HelpLine, a trained specialist will speak to you and prepare a summary of your call. If you choose to remain anonymous, the report will not identify you. (Of course, giving your name can often help us investigate the matter, and as explained below, CBRE has a zero tolerance policy for retaliation for raising a concern under the SOBC.) The call summary is then forwarded to a Compliance Officer to follow up on the matter. We will attempt to respond to your call very quickly, particularly when the nature of the concern makes speed important. If an investigation is undertaken, we will look into the issue promptly and, whenever called for, see that corrective action is taken.
Zero Tolerance for Retaliation
If you seek advice, raise a concern or report misconduct, you are doing the right thing. The commitment to our RISE values includes providing an opportunity for employees to express their concerns and report misconduct without fear of retaliation. Therefore, you will never face retaliation for raising a concern, reporting a violation or participating in an investigation. Retaliation is usually defined as an “adverse employment action” or any action affecting the terms or conditions of employment (e.g.,termination, suspension, demotion or reduction in compensation). Any employees attempting to engage in retaliatory action will be subject to disciplinary action, up to and including termination. If you suspect that you or someone else has been retaliated against for raising any legal or business conduct issue, immediately contact us through one of the avenues we have made available on the left-hand side of each page of the SOBC.
Investigation of Reports
If a report regarding violation of policy or law is received, it will be investigated and documented in accordance with CBRE's approved investigation procedures. Once an allegation of serious misconduct is logged into our system, we will conduct a prompt, thorough, consistent and unbiased investigation. These investigations are conducted by appropriate internal personnel or outside experts who will work in conjunction with the Compliance Department. Employees are not permitted to conduct their own investigation into the matter without permission from the Legal department. CBRE personnel are expected to provide full cooperation and truthful answers in an investigation, and failure to do so will result in disciplinary actions, up to and including termination. We will, where practicable and permissible, endeavor to keep the person reporting the issue apprised of the progress and outcome of the investigation. Consistency of process and outcomes in investigation is achieved by requiring our investigators to attend annual training and regular case peer-review meetings. If corrective action is required as a result of the investigation, we will determine the appropriate steps to take (including, when appropriate, legal action) to stop the ongoing violation, rectify a problem that already occurred, and reduce the likelihood of its reoccurrence.
CBRE's Ethics and Compliance Program
The SOBC is the centerpiece of a global initiative called the Ethics and Compliance Program. The Program was adopted by our Board of Directors in 2004, and the Board maintains active oversight over its implementation and operation. Our Ethics and Compliance Program is designed to reinforce our RISE values—Respect, Integrity, Service and Excellence— and ensure compliance with Company policies, and the laws and regulations that apply to us globally. The Program is designed to accomplish four objectives:
- Mitigate the risk of potential compliance failures
- Minimize the consequences of compliance failures
- Identify and correct compliance deficiencies
- Foster enterprise-wide ethics and compliance accountability.
The elements of our Ethics and Compliance Program are:
- Senior-level ownership and Board oversight
- Standards and policies
- Monitoring and auditing
- Whistleblower Program with multiple avenues for reporting violations
- Investigation of suspected misconduct
- Enforcement of standards and policies through discipline and incentives
- Ongoing risk assessments and continuous improvement
The Program is administered by our Chief Compliance Officer. The Chief Compliance Officer makes regular reports to the Board of Directors regarding the operation and effectiveness of the Program. The Chief Compliance Officer works closely with our legal professionals, senior officers and other personnel involved in relevant areas at each of our business units. The Chief Compliance Officer also establishes the standards for the ethics and compliance programs that will be implemented in each country and region in which we operate worldwide.
Compliance with The Law
No excuse or pressure justifies breaking the law or encouraging someone else to do so. Wherever CBRE has an internal policy that is stricter than what is required by local law, you are expected to follow CBRE's standard. In providing real estate services, local laws govern almost all aspects of our business activities. Violation of local licensing laws could subject you, your colleagues and CBRE to possible fines, sanctions and loss of the ability to maintain a real estate license. Please consult the Legal Department if you are unsure about a potential course of action when navigating the often confusing area of compliance with the license requirements in your country or state.