CBRE Group, Inc., including each of its divisions, business units, affiliates and subsidiaries, (collectively, “CBRE”) is firmly committed to conducting business with the highest integrity and in compliance with the letter and spirit of the law. As an industry leader and a responsible business, CBRE seeks to use its position to promote the highest standards for ethics and business conduct wherever CBRE operates. As a supplier of products and/or services to CBRE, your company (“Supplier”) is critical to CBRE’s success. For CBRE to provide superior services in a responsible manner, CBRE requires Supplier to comply with this Supplier Code of Conduct (this “Code”).
This Code sets forth CBRE’s fundamental ethical and business conduct requirements for its suppliers. This Code is not intended to be an exhaustive list of all requirements to be followed by Supplier, but rather a high-level overview of such requirements. All references in this Code to “Laws” means all applicable laws, regulations, directives, rules, decrees, and governmental orders.
Supplier is responsible for ensuring that their directors, officers, employees, agents, representatives, suppliers, subcontractors, and other business partners understand, and comply with, the requirements set forth in this Code. Supplier will promptly notify CBRE in writing of any known or suspected violation of this Code.
Supplier must compete strictly based on the merits of their products and services. Supplier must never offer, promise, authorize, or provide, directly or indirectly, anything of value (including, without limitation, business gifts or courtesies) with the intent or effect of inducing anyone (including, without limitation, a CBRE customer, CBRE employee, or higher tier or sub-tier supplier) to forego their duties and provide unfair business advantage to CBRE, Supplier, or others. Accordingly, Supplier will, and will cause its employees, representatives, and subcontractors to, comply with all Laws relating to anti-corruption, anti-money laundering, and the prevention of fraud and other financial crime (including tax evasion and its facilitation), in all of the countries in which any affiliated business or associate of the Supplier provides products or services, directly or indirectly, and any other countries in which Supplier conducts business.
Supplier must not engage in any illegal anti-competitive conduct or deceptive trade practice for any reason whatsoever, whether on behalf of CBRE, Supplier, or others. Accordingly, Supplier must never rig bids, fix prices, or provide or exchange customers’, CBRE’s, Supplier’s, or others’ competitively sensitive information (including, without limitation, price, cost, and technical data) with CBRE’s competitors or competitors of Supplier. Supplier must also refrain from abusing their market power, whether for their benefit or for the benefit of others, by refusing to deal fairly, engaging in predatory or discriminatory pricing practices, conditioning the sale or provision of a product or service with that of another product or service, or undertaking similar abusive tactics. Supplier must not engage in other deceptive or unfair market practices, whether on behalf of CBRE, Supplier, or others. Further, Supplier must never make any misrepresentations relating to the products or services of CBRE, Supplier or others. Similarly, Supplier must never denigrate CBRE’s competitors or Supplier’s competitors, or their products or services.
Supplier must properly protect the confidential, proprietary and personal information it handles or otherwise processes by implementing appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including, without limitation, the risk of accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to such information (a “Data Breach”). Supplier must only engage other suppliers and subcontractors who ensure the same level of technical and organizational security.
Supplier must, without undue delay, notify CBRE if it reasonably suspects a Data Breach of any information handled or otherwise processed by Supplier on behalf of CBRE or CBRE’s clients or customers, regardless of Supplier’s assessment of the impact or risk of such breach. Supplier must make available to CBRE, its clients or customers, all information reasonably requested to assist in the investigation and remediation of such breach and ensure compliance with all obligations under applicable law.
Suppliers are expected to create and maintain complete and accurate records to ensure accountability, and not alter or omit any record to conceal or misrepresent the information, event or transaction documented. Records must be retained and deleted in accordance with applicable law.
Supplier must comply with all applicable data protection, privacy and information security laws and regulations (collectively, “Data Protection Laws”) including, without limitation, such laws pertaining to CBRE customers, CBRE employees or other suppliers, and shall not render any service in a manner that causes CBRE to violate applicable Data Protection Laws.
Supplier must promptly notify CBRE if Supplier has reason to believe that laws or regulations applicable to Supplier in the countries in which it operates or renders services (whether existing or as a result of changes to existing law) either prevent Supplier from, or likely have a substantial adverse effect on Supplier complying with, applicable Data Protection Laws or the terms of Supplier’s contract with CBRE.
Supplier must avoid all conflicts of interest or situations giving the appearance of a conflict of interest when doing business with CBRE. Supplier must promptly report to CBRE any instances involving actual or apparent conflicts of interest between Supplier’s interest and those of CBRE, such as a direct personal or financial interest in a business decision or vendor selection. Likewise, Supplier shall not, without prior written notification thereof to CBRE, enter into any business relationship with any director, employee, or representative of CBRE that may create a conflict with their fiduciary obligations to, or the interests of, CBRE.
Supplier must follow all applicable Laws in the countries in which it operates, and be committed to the value of, and respect for, all people. Supplier is responsible for respecting human rights in its operations and will comply with the standards set forth in the United Nations Universal Declaration of Human Rights. The standards set forth in this Code apply to all workers, including, without limitation, temporary, migrant, student, contract, direct employees, and any other type of worker of Supplier. The applicable labor standards are:
Supplier must comply with all health, safety, and security Laws of the jurisdictions in which it does business and limit worker exposure to potential safety hazards (including, without limitation, electrical sources, fire, heat, vehicles, and fall hazards) through proper design, engineering and administrative controls, preventive maintenance and safe work procedures. When necessary to safely perform a job, Suppler will provide workers at no cost and as appropriate the proper personal protective equipment and ensure proper maintenance of the equipment. Supplier employees must be free to raise safety concerns without fear of retaliation in any form. Supplier will record, track and report all occupational injuries and illnesses as required by applicable Laws and in a manner which will: (i) encourage worker reporting of job related injuries; (ii) classify and record cases of injury and work-related illness; (iii) provide necessary medical treatment; and (iv) investigate and implement corrective actions to eliminate their causes.
Supplier recognizes that adverse effects on the community, environment and natural resources must be minimized to safeguard the health and safety of the public. To achieve this objective, Supplier shall observe and comply with all applicable environmental Laws, including, without limitation, those which relate to (i) obtaining and maintaining required environmental permits, approvals and registrations, as well as complying with applicable operational and reporting requirements; (ii) the handling, removal, transportation and disposal of hazardous materials used by Supplier; and (iii) monitoring, controlling, treating and sanitizing air emissions, waste water and solid wastes. Supplier will seek opportunities that promote the efficient use of resources and energy, as well as clean and low energy solutions.
Supplier shall not give to or receive from any director, employee, or representative of CBRE any gift, entertainment, or other favor of material value, or any commission, fee, or rebate, with the intent or effect of inducing anyone to forego their duties and provide unfair business advantage to CBRE, Supplier, or others.
CBRE does not assume any duty to monitor or ensure compliance with this Code. Supplier acknowledges and agrees that Supplier is solely responsible for full compliance with this Code by Supplier’s directors, officers, employees, representatives, suppliers, contractors, and other business partners. Supplier will nonetheless permit CBRE and/or its representatives to assess Supplier’s compliance with the expectations set forth in this Code when rendering services or furnishing products for CBRE. Such assessments may include, without limitation, on-site inspection of Supplier facilities and review of related Supplier information, including books, records, certifications, permits, and other documentation evidencing Supplier’s compliance with this Code. Supplier will also fully cooperate with CBRE in such assessments, and Supplier will promptly correct any non-conformances identified during such assessments.
If this Code conflicts with the terms of any Supplier contract with CBRE, and the contract term is more restrictive than this Code, the Supplier must comply with the more restrictive term of the contract.
For questions or concerns about this Code, including its application to specific circumstances in connection with your organization’s performance of work for CBRE, or to report any suspected violations of this Code, please contact your CBRE representative.
CBRE provides a confidential and anonymous method for employees and stakeholders (including suppliers, sub-contractors, and their employees) to ask questions and raise concerns about CBRE’s Standards of Business Conduct via the CBRE Ethics HelpLine. The CBRE Ethics HelpLine is operated 24/7 by EthicsPoint, an independent company. Global toll-free phone numbers and an online reporting tool can be found here.