Our confidential and proprietary information gives us a competitive edge in the marketplace. It would harm the Company if it were disclosed inappropriately. In addition, as a public company we must be extremely careful that we control the disclosure of material information about our business. Company policy requires all of us to keep CBRE's confidential information secure. This applies to information about our finances, strategies, operations, clients and compensation. It also applies equally to information belonging to our employees and clients.

These days most confidential information is in the form of electronic data stored on our computers and other devices. Our IT Department is continually improving our systems to protect sensitive information from unauthorized access. Most protection occurs behind the scenes and we don't even notice it, but each of us must play our part and take common-sense steps to prevent the loss or unauthorized use of sensitive information. There are laws in many countries that dictate what to do if any of our IT systems have been breached, and these laws may be triggered if your computer, laptop or mobile device is lost, stolen or accessed by an unauthorized user. Therefore, please be knowledgeable about your responsibilities to keep CBRE's information systems and devices secure, and what to do if they are compromised.

Each employee is required to sign an acknowledgement of his or her responsibilities to keep our information confidential. The obligations under this policy continue even after the employee leaves CBRE.

A few words of wisdom about securing our confidential information:

  • Remember to mark all proprietary information as "Confidential." All electronic mail documents must be treated similarly to sensitive paper documents.
  • Be aware of who might be listening when you are speaking about confidential matters—never talk about confidential matters in public areas such as elevators, taxis or restaurants. If you must, change names or speak in code.
  • Do not share confidential information even within CBRE unless you are sure that the recipient has the need to know that information. If you are about to make them “inside” on information, then you need to tell them before disclosing the information.
  • If you are required to disclose confidential information to a third party in the course of your job, you should do so only under a written non-disclosure agreement in a form approved by the Legal Department.
  • Do not leave confidential information lying visibly on your desk or other places where it can be seen by unauthorized persons. Follow required procedures for safeguarding and disposing of confidential information, rather than throwing it away in an ordinary garbage can.
  • Never share your passwords with another person.
  • Avoid accessing questionable websites when using company computers.
  • Avoid transferring company data to a personal computer.
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Our Confidential and Proprietary Information Check your knowledge

Your brother, Milo, has a printer business, he sells printers to companies. A week ago, he took you out for dinner and confided that times have been tough lately. Sales have dropped off and he is running out of leads. Milo asks you to help him by giving him one of CBRE's local marketing lists. "The information is public anyway, but it will save me weeks worth of time if I could get the list from you since it has already been compiled," Milo tells you.

Should you give the marketing list to Milo?

Yes No
Correct Answer — No

Even if the information is public, it has been compiled, organized, and formatted in a way that is of significant value and gives us an advantage in the marketplace. You should not give Milo a copy of the marketing list.

Alana, a broker, has asked her assistant, Gilbert, to go through her address book and "clean it up" by getting rid of contacts she has not talked to in over 5 years. Gilbert decides to do the work at home, so he prints out the address book and leaves the office. Gilbert inadvertently leaves the printed book on the top of his car and drives away. The printed address book is distributed along the highway for the next three miles.

Is Alana's address book proprietary information?

Yes No
Correct Answer — Yes

The address book contained all business contacts and is vital to Alana's success as a broker. Gilbert has a duty to protect that information.

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