Elevate Your View Spring Crossing
of Elevate Your View
Spring Crossing is the true gateway to north Houston. It offers the most visibility and experiences the most activity at a juncture where I-45, Grand TC Parkway and the Hardy Toll Road converge to access the northern part of the City with No Limits.
To position Spring Crossing according to its strengths, Skanska needs a partner that understands the true value of the property compared to neighboring properties like Springwoods Village and the Woodlands. A partner that can turn your vision of Spring Crossing as a superior workplace destination into a reality. We will elevate every property strength to connect Houston’s office brokers and tenants to an opportunity where they believe and act on Skanska’s goals for Spring Crossing: Page 4 ...... The Team 01 BE SEEN. BE NEXT. BE HERE. Page 10 ...... Reporting 02 Page 12 ...... Strategy & Approach 03 Page 18 ...... Competing Assets 04 Page 20 ...... CBRE’s Code of Conduct 05 Page 22 ...... Sell the Story 06 At Spring Crossing, we Page 32 ..... Recommend Rates & Terms 07 will Elevate a Vision that Page 38 ...... Strengths & Challenges 08 inspires tenants to: Page 40 ...... Fees & References 09 Be Seen. Be Next. Be Here. Page 44 ...... Appendix 10 The Team
Detail the team structure (staffing requirements), identify experience and qualifications of the professionals, and reporting relationships for CBRE’s proposed team.
Partnered for Success
Advisory & transaction Dedicated executive leadership SOURCING & SECURING THE RIGHT TENANTS OVERSIGHT & STRATEGY
01 SPOC CODY ARMBRISTER WARREN SAVERY Senior Managing Director THE TEAM Senior Vice President MARK TAYLOR RIMA SOROKA Senior Managing Director Vice President
Market intelligence Marketing AN ELEVATED VIEW DELIVERING ACTIONABLE, CREATING ENGAGING VIRAL FORWARD-LOOKING INSIGHT CAMPAIGNS
ROBERT KRAMP AMY MOCK Director of Research & Analysis Marketing Director
ANGIE BAUER-HAMILTON TIM GARFIELD Research Team Lead Marketing Manager
4 01 | THE TEAM 01 | THE TEAM 1 SOURCING & SECURING THE RIGHT TENANTS CHANNELING NATIONAL OPPORTUNITIES
WARREN SAVERY CODY ARMBRISTER SENIOR VICE PRESIDENT SENIOR MANAGING DIRECTOR SINGLE POINT OF CONTACT 12 YEARS’ EXPERIENCE EXECUTIVE OVERSIGHT 35 YEARS’ EXPERIENCE
Warren Savery recently rejoined CBRE with a focus on high profile Class A assets. Warren Cody Armbrister serves as the Senior Managing Director for the Houston market. In this role, specializes in landlord representation and has leased notable Houston projects such as Four Cody oversees the firm’s Houston operations, which encompass two offices and more than Oaks Place, The Galleria Office Complex, AIG Center, One Riverway and Eldridge Place. Prior 600 employees. His responsibilities include oversight of all lines of business including Brokerage, to joining CBRE, he served as Senior Vice President-Leasing for Cousins Properties, Incorporated Capital Markets, Property and Facilities Management, Valuation, and Project Management. and was commissioned with leasing responsibility for Greenway Plaza and Post Oak Central totaling over 6.5 million sq. ft. Warren has negotiated some of Houston’s largest office leases Previously, he led the CBRE Houston Office Agency Leasing Team and worked with many of the including Invesco for 400,000 rentable sq. ft. and Occidental Petroleum for 950,000 rentable sq. market’s top institutional and private investor clients, as well as with many developers, on some ft. Recently, Warren and the CBRE team began the leasing efforts for Capitol Tower in downtown of Houston’s most high profile office projects, resulting in undisputed new construction leasing Houston. The building is being kicked off with a lease with Bank of America/Merrill Lynch for success in the past 10 years. Consistently a top performer for CBRE in the Houston market, he has 210,000 sq. ft. been a top 250 producer in the Americas for the company for several years. Over his career, he has completed more than 625 office leases totaling more than $2.75 billion in value.
RIMA SOROKA VICE PRESIDENT MARK TAYLOR SENIOR MANAGING DIRECTOR 10 YEARS’ EXPERIENCE 30 YEARS’ EXPERIENCE EXECUTIVE OVERSIGHT
Over the course of her 10 year career, Rima has represented many of the country’s most prominent and successful real estate companies, which includes institutions, equity funds, Mark Taylor is the Market Leader for CBRE Houston’s Investor Brokerage Services, Investment private owners and developers. Her client-centered approach drives a growing portfolio of Properties, Capital Markets, and Asset Services business units. Mark joined CBRE in early 2007 as office product in the Greater Houston area; to date she has created more than $500 million in a result of the company’s acquisition of Trammell Crow Company. With CBRE, Mark oversees a value by executing on major leases for her clients. Rima and her team specialize in the pre- staff of approximately 400 real estate professionals that provide solutions and create value for leasing of new construction and asset repositioning for existing Class A and B office product. owners of over 45 million sq. ft. of office, industrial and retail space, serving Institutional owners, developers, property users and real estate investors throughout the Houston/Gulf Coast region. Notably, Mark led the leasing team for the preeminent corporate campus development for BMC. He is responsible for ensuring clients’ brokerage, real estate management, property disposition, financing, asset disposition and property acquisition requirements are met.
In addition, Mark also oversees CBRE’s Healthcare practice in Houston, responsible for the leasing, property management, construction management, and other real estate services for Houston’s leading healthcare provider.
2 01 | THE TEAM 01 | THE TEAM 3 ACTIONABLE, FORWARD-LOOKING INSIGHT
ROBERT KRAMP TIM GARFIELD DIRECTOR OF RESEARCH & ANALYSIS MARKETING MANAGER
18 YEARS’ EXPERIENCE 6 YEARS’ EXPERIENCE
Robert Kramp serves as the Director of Research & Analysis for CBRE’s Texas and Oklahoma Tim Garfield is a CBRE Marketing Manager for the Houston region. In this role, Tim manages the region. In this role, he is responsible for regional research thought leadership, building upon creation and implementation of high-quality marketing strategies and deliverables, including existing CBRE Research capabilities to guide real estate strategies, identify risks and validating proposals, property marketing brochures, advertising and web-based initiative. Tim serves as the decision-making. His focus includes economic development, business development and Houston office strategist and point of contact for new business initiatives. marketing. He also spent four and a half years in economic development and research with the Greater Houston Partnership, the city’s preeminent economic development organization.
ANGIE BAUER-HAMILTON RESEARCH TEAM LEAD Notable Representation 5 YEARS’ EXPERIENCE Experience
Angie Hamilton serves as Research Team Lead for the CBRE Houston market, overseeing day-to-day research operations and database management and working closely with local leadership to facilitate cross WARREN SAVERY RIMA SOROKA collaboration and ensure internal and external client needs are met. Angie works with a diverse research team tasked with market analysis, quarterly analysis and reporting, and data integrity to PROPERTY SQ. FT. PROPERTY SQ. FT. support research needs for the brokerage, capital markets, investment properties, valuation and Greenway Plaza (10 Bldgs) 4,300,000 666 Fifth Avenue (NYC) 1,500,000 asset services divisions. Prior to becoming Team Lead, Angie was a Research Analyst focusing on AIG Campus (4 Bldgs) 2,200,000 40 Wall Street (NYC) 1,300,000 the office line of business. In her role, Angie maintained the office database, calculated quarterly Four Oaks Place (3 Bldgs) 1,700,000 Lakes on Post Oak numbers to track industry information, trends and statistics for the Houston market and completed 1,200,000 Lakes on Post Oak (3040, 3050, 3000) focused research and analysis for client reports and meetings. 1,200,000 (3040, 3050, 3000) Marathon Oil Tower 1,200,000 Galleria Towers (2700 Post Capitol Tower 775,000 Oak, Galleria Financial 1,200,000 730 Third Avenue (NYC) 630,000 CREATING ENGAGING VIRAL CAMPAIGNS Center, Galleria Tower) Beltway Lakes III and IV 520,000 Post Oak Central (3 Bldgs) 1,200,000 Southwest Corporate Center 500,000 AMY MOCK Eldridge Place (3 Bldgs) 850,000 2603 Augusta (Repositioning) 240,000 MARKETING DIRECTOR Capitol Tower 775,000 8 West Centre 227,000 Weslayan Tower 500,000 1330 Enclave 200,000 9 YEARS’ EXPERIENCE One Riverway 500,000 Westchase Corporate Center 185,000 Briar Lake Plaza 500,000 Amy Mock services as CBRE’s Marketing Director for the Houston region. 777 Post Oak 175,000 She manages a team of account managers, writers, designers and Travis Tower 474,000 communications professionals, responsible for the business development 1001 West Loop South 462,273 initiatives supporting commercial real states brokers in Texas, Oklahoma and One West Loop Plaza 281,590 Arkansas. In this role, Amy oversees daily operations and oversight of 28 marketing professionals serving over 365 brokers in eight markets.
4 01 | THE TEAM 01 | THE TEAM 5 PROPERTY INFORMATION ROLE & RESULTS
CAPITOL TOWER Awarded leasing assignment in August 2016. Seamlessly integrated with Skanska team and quickly CLIENT: generated the first tenant to kick off construction of the building. Skanska Have increased awareness surrounding the project, and 775,000 SF created a buzz that is generating strong prospects for the 27% Pre-leased remainder of the development.
HESS TOWER Assisted in sourcing premier land sites and speculative equity partners; participated in key design/development meetings. CLIENT: Partnered with outside marketing firm to develop a Trammell Crow Co. / strong brand identity and creative marketing plan to Principal Real Estate secure targeted tenants. Investors Created competitive leasing program, whereby multiple 844,000 sq. ft. tenants demanded the same space; leveraged landlord’s 100% Pre-leased position and achieved above-proforma rates with tenant taking more space than initially desired; achieved highest sales price per foot at time for CBD office tower. n ENERGY CENTER Identified the best possible development site in the submarket III & IV as well as underwriting and supporting lender financing. Provided preconstruction consulting and design input. CLIENT: Trammell Crow Co. / Assisted in brand development and delivered best-in-class Principal Real Estate marketing programs; leveraged multiple tenants vying for same A Record of space, which allowed ownership to select best credit tenant Investors at most advantageous deal terms; created opportunity to 546,372 sq. ft. develop second building (ECIV) within one lease transaction; achieved highest ever sales price per foot at time for Suburban Success 600,000 sq. ft. office trade. 100% Pre-leased NOBLE ENERGY CBRE negotiated sale to TCC & Principal Investors; new owners CENTER I & II then hired CBRE to lease the building. Repositioned, marketed and leased 100% to Noble Energy who CLIENT: then contracted with TCC to build Noble Energy Center Two. Trammell Crow Co. / Principal Real Estate Provided property management services and eventually hired Investors to sell the property.
550,000 sq. ft. I: 100% Pre-leased II: 100% Pre-leased Summarize any previous PLAZA AT Consulted extensively on pre-design modification and downtown/new ground-up ENCLAVE participated in pre-development meetings; partnered development experience of a with ownership to maximize the property’s appeal among prospective tenants and delivered best-in-class marketing to size similar to Spring Crossing CLIENT: build awareness. by the proposed team CORE Real Estate Identified issue and implemented a timely modification to 354,000 sq. ft. correct a LEED design feature issue for a smooth tenant move-in. 82% Pre-leased Secured Fortune 50 client with DOW on long-term lease; allowed ownership to dispose of property at record-breaking number for Suburban office building transaction at time.
6 01 | THE TEAM 01 | THE TEAM 7 PROPERTY INFORMATION ROLE & RESULTS PROPERTY INFORMATION ROLE & RESULTS
ENERGY CENTER EC I: 9090 KATY Targeted and secured tenants, developed marketing plans Facilitated LEED Silver certification five months after I & II FREEWAY and advised on building finishes, lobby construction, and construction; entire Phase I project was 100% leased to Foster parking functionality for successful pre-leasing. Wheeler USA before structural topping out. CLIENT: CLIENT: Trammell Crow Co./ EC II: ERSA GRAE Principal Real Collaborated with TCC to obtain LEED Gold certification; Estate Investors implemented cost saving design and construction features; 94,000 sq. ft. property was 46% leased prior to core and shell completion. 100% Pre-leased 332,000 sq. ft. 305,595 sq. ft. I: 100% Pre-leased II: 46% Prior to core and shell completion 3 ELDRIDGE Developed a marketing center at the existing 2 Eldridge to This following list represents experience by current cbre professionals host catered broker luncheons onsite for tenant rep firms; CLIENT: delivered an experience through renderings and virtual video while at former firms. tour. Behringer Harvard Once 100% leased, the marketing center was converted into a CITY CENTRE 98% leased across City Centre I-IV within one year of delivery. 305,528 sq. ft. conference center for the entire business park. 100% Pre-leased I, II, III, IV, V Selectively chose ideal tenants to achieve proforma rates and secure BP as the chief building tenant. CLIENT: Midway
3009 POST OAK Delivered innovative branding and marketing, including a 3D 650,000 sq. ft. tour-supported, multi-faceted campaign. 98% Pre-leased CLIENT: Generated strong market interest quickly with multi-tenant Skanska lease up success. KIRBY GROVE Pre-leased City Centre 5 to 75% upon delivery at 304,000 sq. ft. pro forma rates. 88% Pre-leased CLIENT: Midway
240,000 sq. ft. 8 WEST CENTRE Applied local market knowledge to identify the appropriate 65% Pre-leased long-term building tenants to achieve their specific exit goals; locked lead tenants within two months of the start of building CLIENT: construction. CORE Real Estate Achieved 100% occupancy within five months of beginning BOULEVARD Leveraged amenity base to target best-fit tenants and 227,059 sq. ft. building construction. achieved 100% occupancy. 100% Pre-leased PLACE CLIENT: Wulfe & Company
17000 KATY Provided in depth involvement throughout the design and 150,000 sq. ft. FREEWAY development process. 100% Pre-leased Applied creative leasing and marketing services for pre-leasing CLIENT: success. CORE Real Estate
180,000 sq. ft. 100% Occupied upon completion
8 01 | THE TEAM 02 | REPORTING 9 Reporting
Detail communication/ responsiveness plan for Spring Crossing.
e will regularly update BENEFITS OF VTS you through active and daily communication and • Centralized Deal Management bi-weekly meetings. W • Shareable, Responsive Marketing Materials Additionally, we will work together to develop leasing strategies and plans to lay • Integrated Asset Landing Pages the ground work for our marketing strategy. • Complete Asset Intelligence • Powerful Alerts and Notifications Our leasing team utilizes VTS, an all-in-one tracking platform, where deal activity • Automated Leasing Activity Reports can be accessed in real-time. We were • Streamlined Deal Management a CBRE “beta site” for VTS and pioneers • Mobile Access and Proactive Alerts for this technology in our market. As early • Automated Listing Syndication adopters, we’ve become adept at fully leveraging VTS to adapt and modify our • Actionable Marketing Insights 02 leasing strategies for maximum efficiency.
REPORTING Through VTS, proposals, tours, and day- to-day deal activity are managed and monitored and can be accessed via mobile app or website 24/7. As our client, you will be fully integrated into every move regarding the leasing at Spring Crossing with full visibility of our productivity and AN ELEVATED action through this technology. In addition VIEW to VTS, we will host meetings and/or calls at a frequency level comfortable to you.
10 02 | REPORTING 02 | REPORTING 11 Strategy & Approach
What is your firm’s leasing strategy for the project?
What is the project’s primary selling point/differentiator?
Relationship-driven. This isn’t just what we say, it’s who we are at our core; it is our client-centric culture and business philosophy. We communicate regularly, both across service lines and among all echelons of our organization— • We are not conflicted continuously exploring new ways of enhancing the value and have the equation for our clients and their assets. It is this spirit of capacity and time collaboration with the goal of achieving mutual success to provide Spring that guides every client relationship. Crossing the attention Target tenants with precision it deserves. • CBRE is engaged 03 Through a systematic approach to finding and capturing with 89% of the opportunities, we rapidly know which tenants are on Fortune 100—we can the move, where they are looking, and if they are a fit STRATEGY & quickly connect with for Spring Crossing. We track all the major users through decision makers at our extensive market research capabilities and existing APPROACH organizations that are relationships through our specialized practice groups and difficult to navigate. service lines.
• CBRE’s in-house Our strategic plan will include getting out in front of Research team tracks expirations and monitoring the movement of anchor every tenant in the tenants followed by secondary tenants that would be a AN ELEVATED market. We will use our good fit for Spring Crossing. Among the tenant types that expansive database VIEW will be pursued in our strategic efforts are primarily energy to directly contact the and energy related companies, technology, healthcare, most likely prospects. business services, and HQ relocation opportunities.
• Additionally, we will use the traditional “streets to suites” method by cold-calling our coverage is and campaigning prospects. your advantage
12 03 | STRATEGY & APPROACH 03 | STRATEGY & APPROACH 13 TENANTS IN THE Capture tenants MARKET with speed We will target Waterway and other Woodlands tenants who want to be closer to Houston. Additionally, we will go global business practices after Greenspoint tenants impacting occupancy looking for an upgraded requirements. This insight allows us to continuously 250K - 300K SF I EXP. 1/31/2020 environment. evolve our marketing CBRE’s expansive network strategies and tactics of specialty experts, here and ensures that we can develop an effective and around the globe, is MARKET SHARE connected with intent and leasing strategy to act by organizational design. swiftly, capture targeted tenants and generate Local market intelligence LANDLORD Representation TENANT Representation provided through real volume, velocity and value estate professionals in for Spring Crossing. every major market across Spring Crossing will be 150K SF the globe, combined with the insight gleaned rapidly promoted to our from CBRE’s Occupier internal and external % % Services group and other networks and targeted specialty practices, helps client base—exponentially our project team stay multiplying the number of 20 24 current with user migration people working for you at HOUSTON OFFICE MARKET and space needs, lightening speed. emerging technologies, 120K - 150K SF production processes and Top 10 CBRE Transactions
COMPANY BUILDING NAME TOTAL SQ. FT. ConocoPhillips Co Energy Center III & IV 1,146,313 Noble Energy Inc. Noble Energy Center I & II 1,000,000 In any new development, Hess Corp. Hess Tower 844,000 landing that elusive first deal Bechtel Corp. 3040 Post Oak 565,916 National Oilwell Varco Inc. Millennium II 415,832 will validate your asset, reinforce LyondellBasell Houston Center 360,000 15K SF your brand, and encourage Dow Chemical The Plaza at Enclave 279,484 other end-users to buy in. Bank of America Capitol Tower 210,000 Stage Stores 2425 WLS 190,000 There isn’t a major tenant that Mustang Engineering 17000 Katy Freeway 170,000 we don’t know or have a key PWC Wells Fargo Plaza 170,000 Alliant Group 3009 Post Oak Boulevard 125,170 relationship with.” Denotes deals where CBRE represented both the Landlord and Tenant. Denotes deals where CBRE represented the Landlord. 14 03 | STRATEGY & APPROACH 03 | STRATEGY & APPROACH 15 Denotes deals where CBRE represented the Tenant. It’s all Community at Spring Crossing SELLING POINTS/DIFFERENTIATORS
Attractive to a multitude of Will provide a campus-style When completed, Spring Crossing will offer a corporate- k tenants seeking efficiency k environment that employees and modern design will look forward to collegial environment, in a campus setting that warmly invites the office community to feel comfortable in their social surrounding. Spring Crossing will unfold as a neighborhood that Will be attractive to the 4/1000 parking ratio to unifies and inspires the business community to collaborate, k modern workforce who k adequately serve today’s innovate, implement and–thrive. seeks a corporate-collegial workplace density environment
Strength of robust and Ease of access for k flexible ownership k commuters and excellent view corridors
In a corporate collegial environment
16 03 | STRATEGY & APPROACH 03 | STRATEGY & APPROACH 17
Aerial view of the campus Competing Assets
Provide a list of competing assets for which your firm and your firm’s proposed team are currently representing or likely to be representing during the period of engagement.
We are confident that our focus on Spring Crossing will produce quantifiable results for Skanska. Although CBRE, as a whole has extensive listing exposure in Houston, this is a huge benefit for you. We know every deal that’s happening, and the pricing and terms associated with them, in every corner of the 04 market. We have carefully reviewed CBRE’s North Houston assignments, COMPETING shown below, and the proposed team ASSETS members have no direct conflicts.
SUBMARKET CLASS ADDRESS PROPERTY PROJECT CURRENT ROLLING OWNER CBRE TEAM AN ELEVATED NAME SQ. FT. AVAILABILITY SQ. FT. VIEW Woodlands A 460 + 480 Wildwood 81,039 RSF 8.9% No Geosouthern Jason Presley Wildwood Corporate immediate roll Wildwood LLC Debbie Wison Forest Centre Steve Rocher Drive Wildwood 201,651 RSF Corporate Centre II
TOTAL 282,690 RSF CLASS A
18 04 | COMPETING ASSETS 04 | COMPETING ASSETS 19 CBRE’S Code of Provide copies of your firm’s code of conduct, ethics, and Conduct other associated policies.
RISE VALUES
We take great pride in our reputation for upholding the highest standards in the way we do business.
Our commitment to our business standards is a major reason why we’re the largest commercial real estate company in the world. Our employees don’t just work and live by these standards, they are the cornerstone of our RISE corporate values:
• RESPECT: Treat everyone with dignity, value their contributions and help one another succeed. • INTEGRITY: Uphold the highest ethical standards in our business practices. 05 • .SERVICE: Dedicate ourselves to making a meaningful impact on our clients and in our communities. CODE OF • .EXCELLENCE: Aspire to be the best in everything we do and strive for continuous improvement.
CONDUCT Our values are timeless and transcend all markets, service lines, languages and business cultures. They are present in everything we do and drive our success.
Managing Conflicts of Interest AN ELEVATED Because of our deep market presence and far-reaching We take our roles as your VIEW relationships, CBRE is adept at balancing widespread activity advocate and trusted steward within the marketplace. very seriously.
In the course of doing business, it’s inevitable that we will face It is ingrained in the CBRE situations that pose or have appearance of posing potential culture and our core RISE values conflicts of interest and how we respond to and manage (described above) to keep your conflicts is not just a set of policies and procedures; it’s a way business and operational goals at of doing business that is fundamental to our success. When the forefront of every interaction. we make decisions as to what assignments to accept and how to manage conflicts, if and when they arise, we will See Appendix for complete always adhere to our fiduciary duties and place the interests documentation on Standards of of the client we represent ahead of our own. Business Conduct and Managing Conflicts of Interest.
20 05 | CODE OF CONDUCT 05 | CODE OF CONDUCT 21 Sell the Story
IDENTIFY your firm’s Share feedback on whether Please provide CANDID 1 in-house marketing 2 the existing marketing 3 FEEDBACK on these capabilities. materials can be used as part materials as they relate of the marketing campaign to leasing. or if you recommend new/ additional marketing materials/positioning. MOMENTUM MARKETING
The marketing strategy and tactics for new everyone is inspired to collaborate for success. construction differ greatly from those of an This is where CBRE can provide Skanska a existing building. We have the experience to competitive advantage. We stand-alone in position Spring Crossing for leasing success—and our ability and approach to marketing influence tenants to promptly take action. properties, and we elevate brands through world-class, imaginative campaigns that The marketing for Spring Crossing must leave generate engagement. a powerful impression, matching desired 06 expectations with the occupancy needs of We’re laser-focused on the end result: quickly potential users. Without superior branding, securing anchor and large-block tenants, kick- SELL THE there is no differentiation. The marketing starting the development, and maximizing your efforts to date are first class, but we can take financial returns for the short- and long-term. STORY it a step further and build off of what you’ve We’ll do this by positioning the property through created. We need greater differentiation to an aggressive, proactive, process-driven fully convey the message that Spring Crossing marketing approach. was created to build a world-class community, in a corporate collegial environment where
AN ELEVATED Current marketing assessment VIEW HOME PAGE: PLANS: • Make less formal as submarket is more • Add shot to show visibility when business casual then business formal you’re heading southbound VIDEO: AMENITIES: • Include stills in video that demonstrate how • Need connection to 400,000 SF of close and connected Spring Crossing will be amenities at Springwoods Village by to Springwoods Village offering shuttle service OVERVIEW: SUSTAINABILITY PAGE: • Address amenities or other critically • What do these features mean to the tenant? important factors to tenants SKANSKA PAGE: ACCESS PAGE: • Make this image heavy to showcase the • Consider the interactive access features to work Skanska has done in Houston and 22 06 | SELL THE STORY 06 | SELL THE STORY 23 be more intuitive and user-friendly other notable projects Deliver an MAKE IT REAL
Selling space that doesn’t exist yet—and convincing occupiers to sign on to the project— Experience takes creativity and innovation. Helping prospects to “see” your vision and “feel” the experience that awaits them is crucial. By utilizing leading-edge technology for maximum psychographic effect, you will achieve the all-important trifecta—the three stages we must EXPERIENTIAL MARKETING successfully navigate with prospects to secure preleases for Spring Crossing.
Spring Crossing calls for vibrant and memorable marketing. Experiential marketing transforms your project from GET PROSPECTS EXCITED an abstract, future concept into a living, breathing environment for users. We recommend utilizing a virtual reality headset to allow prospects to take a virtual tour of Spring Crossing’s site, amenities and common areas, and floor plate. We want prospects to have a truly Some ideas that we have to engage captivating experience. brokers and prospects are:
• Build in-town marketing center to cater MAKE IT IMMERSIVE to brokerage community
• Create highly robust virtual mobile Once we’ve grabbed their attention, Igloo 360 technology allows prospects and their brokers to presentation to cater to companies experience a personal 3D tour at Spring Crossing in a full VR setting. Ideal for hosting prospective tenant meetings and marketing events, Igloo allows the viewer to experience Spring Crossing well • Explore additional marketing center in in advance of physical tours. construction trailer on-site
• Explore the site with target prospects MAKE IT PERSONAL via helicopter rides creating a memorable experience To ensure prospects can fully understand what occupying space at Spring Crossing will be like, Floored’s Protofit technology visualizes 2D floor plan configurations and quickly transforms them • 3D-interactive floor plans to build into 3D models in real time. This live, 3D demonstration tool reduces turn-around time for concept tenant spaces designs, eliminates the inefficiencies of other modeling options and spurs prospective users to commit to your project.
24 06 | SELL THE STORY 06 | SELL THE STORY 25 A HEADLINER
PR & ADVERTISING CBRE WILL COLLABORATE CBRE can add value to your creative WITH YOU TO DELIVER efforts. We have deep relationships with A DISTINCT BRAND key media outlets to expose Spring Crossing locally, regionally and nationally. We lead EXPERIENCE FOR THIS ASSET all commercial real estate brokerage firms in terms of print and online media coverage and have a proven track record for generating results. True, strategic marketing is looked over by many, and SOCIAL MEDIA this assignment will require Promotion that utilizes social media sparks unconvential ideas, attention interest, inspires interaction and drives traffic to details, customization and to precisely where you intended—keeping personalization to differentiate Spring Crossing in the forefront and top of mind. As one of the most powerful ways to the project. Our social media connect space to brokers and tenants, we and PR strategy will position will leverage key social media channels to Spring Crossing squarely in front dramatically increase the spotlight Spring Crossing. This isn’t just about generating of existing tenants, prospects leasing opportunities, but a unique strategy and the market—creating to kick-off a campaign and prospective tenants will love the story. anticipation and excitement about the great things happening at the project. EVENTS
We are experts at building momentum around a property. By promoting and hosting Open House events, the CBRE team will educate the market on the new story at Spring Crossing. We will create a buzz and excitement among brokers, prospective tenants and existing tenants—helping to forge new relationships and build trust with ownership, management and leasing teams.
26 06 | SELL THE STORY 06 | SELL THE STORY 27 We know how to capture these needs and captivate tenants with the EXPERIENCE that is to come.
Today’s employees want more than an office. They want an experience—a satisfying, holistic workplace that promotes wellness, sustainability, connectivity and access to the community.
THE WORKPLACE
NEEDS TO SATISFY
The Body The Conscience Productivity WELLNESS SUSTAINABILITY HOLISTIC ENVIRONMENT
MUST TRANSCEND BOUNDARIES
WHAT DO OCCUPIERS NEED? RELAXATION ENTERTAINMENT NETWORKING COLLABORATION COMMUNITY »» Sense of Community »» Elevated Atmosphere STRESS EFFECTS HEALTH, WELLNESS & WELLBEING »» Collaboration Space TOP 3 STRESS FACTORS »» Access to Fun & Entertainment CLAIM STRESS HARMS »» Conducive to Networking 44% HEALTH 1 BALANCING PRIVATE WITH PROFESSIONAL »» Relaxation & Green Space RATE “NORMAL” WORK STRESS »» Accessible Public Transit 53% AS 7 OUT OF 10 »» Health & Wellness 2 HIGH PERSONAL EXPECTATIONS »» Customized Cool Factor Amenities CAUSES 24 SICK DAYS PER ANNUM = 10% OF THEIR WORKING YEAR ALWAYS “ON” DUE TO 24/7 TECH 3 & AVAILABILITY
28 03 | STRATEGY & APPROACH 03 | STRATEGY & APPROACH 29 Make the workday the ULTIMATE occupier experience.
FUTURE TRENDS
GLOBAL WAR FOR TALENT
GROWING, AGING GLOBAL POPULATION
DIY HEALTH
RISING OBESITY WORLDWIDE CBRE SACRAMENTO, CA CBRE LOS ANGELES, CA 24/7 AVAILABILITY & TECHNOLOGY
Experiential Environments— CBRE Walks the Talk The New Normal CBRE leads the brokerage industry TOP 3 BUSINESS BENEFITS A new survey of 229 executives, released in transforming the traditional office in March as part of CBRE’s Americas environment into an experience. Our Occupier Survey, underscores the major specialty practices, such as CBRE’s EMPLOYEE shift in how companies make real estate Global Workplace Solutions, can help CHOOSING AN EMPLOYER 44% decisions. They reported that both access Skanska develop programs and tactics ENGAGEMENT to talent and workplace experience that ensure Spring Crossing fosters dominate today’s corporate real estate creativity and productivity to the fullest STAY LONGER EMPLOYEE agenda, along with escalating costs. As extent—keeping it in high demand. WHERE HEALTH IS a result, 57% see workplace strategy as 62% 57% SUPPORTED SATISFACTION both a critical employee attraction and And we “walk the talk” when it comes retention strategy, and as a means to to advising our clients on the open- control costs. plan, integrated, adaptive layouts THINK WELLNESS SAY THAT A WELLNESS that the evolving workforce demands. 97% STRATEGY ADDS VALUE Among the top rated workplace Over the past two years, we have SUPPORT AT WORK 75% IS IMPORTANT needs include feeling connected to a been installing modern, collaborative community. Spring Crossing has a unique “Workplace360” designs in our offices opportunity to capitalize on a truly around the world. We lead the brokerage BELIEVE WORKPLACE DESIGN corporate collegial setting, where “it’s all industry in transforming the office into 66% IS KEY TO WELLNESS community.” People will feel comfortable an experience. Because we live and and inspired to connect with their breathe placemaking, we can help you office neighbors and maintain a sense make Spring Crossing the place where of belonging while in their workplace. businesses join together in a Spring Crossing maintains the flexibility thriving community. to develop and adapt to meet specific occupier needs.
30 02 | REPORTING 02 | REPORTING 31 Recommended Rates & Terms
Recommend deal terms/leasing guidelines (rental rates, TIs, escalations, free rent, op ex, etc.) and provide a stacking plan with these terms – use and provide recent comparable leases and market statistics to support your recommendations.
The goal is to first secure a relevant and well-known tenant(s) to generate excitement about the building and command the highest rates possible. 07 PROJECTED LEASE RATES & DEAL TERMS RATES & TERMS
n OFFICE RATES/TERMS
AN ELEVATED ASKING: VIEW $24.50 PSF $0.50 ANNUAL BUMPS 130 months 10 months free $70.00 TI
32 07 | RATES & TERMS 07 | RATES & TERMS 33
View of Phase I from Springwoods Village Parkway NORTH SUBMARKET
Class A Asking Rate Class A Vacancy (%) Class A Availability (%) • The North submarket, recently Vacancy (%) Asking Rate ($/SF) coined “Houston’s Second Energy l We have based our 10% 50 Corridor,” was formed in 2014 when ExxonMobil opened up their 3.1 recommended rates and 8% MSF corporate campus. 40
terms on the following 6% • Growth in this submarket picked up with recent developments 30 market information: including Grand Parkway from 4% US 290 to US 59N, Southwestern 20 Energy’s campus in 2014 and most 2% recently, Springwoods Village.
0% 10 • CityPlace 2 started construction on a 326,800 sq. ft. build-to-suit for 2014 2016 2015 ABS and construction will begin YTD 2017 in July 2017 on two buildings totaling 378,000 sq. ft. for HP, all in Springwoods Village. Net Absorption Direct Vacancy Sublease Total Available Asking Gross Rate Class Market Size (SF) Availability (%) (SF) (%) Available (SF) (SF) ($/PSF) Class A 3,945,436 0 7.8 0 308,427 7.8 N/A WOODLANDS SUBMARKET Overall NORTH4,914,759 BELT (19,564) SUBMARKET 9 .4 21,538 485,086 9.9 29.67
Class A Asking Rate Class A Vacancy (%) Class A Availability (%) • The Woodlands is 32% energy- Vacancy Asking Rate ($/SF) related, placing it in third place 25% 45 behind CBD (53%) and Energy NORTH BELT SUBMARKET Corridor (58%) 20% 40 Class A Asking Rate Class A Vacancy (%) Class A Availability (%) • Class A occupancy was close to • New development has halted, Vacancy Asking Rate ($/SF) 100% for more than 10 years, until while the neighboring North 60% 35 15% 35 2014 when ExxonMobil vacated submarket recently announced and moved their 3 MSF campus two build-to-suit projects in 50% 30 10% 30 in the North submarket Springwoods Village. 40% 25 5% 25 • North Belt has rapidly decreased 30% 20 occupancy. Due to an eroding neighborhood, quality tenants 0% 20 20% 15 are considering moving to the 2011 2011 2007 2008 2009 2010 2012 2013 2014 2016 2015 Woodlands.
YTD 2017 10% 10
0% 5 Net Absorption Direct Vacancy Sublease Total Available Asking Gross 2011 2011 2007 2008 2009 2010 2012 2013 2014 2016 Class Market Size (SF) Availability (%) 2015 (SF) (%) Available (SF) (SF) Rate ($/PSF) YTD 2017 Class A 6,578,614 17,540 13.3 213,635 1,085,978 16.5 39.59 Net Absorption Direct Vacancy Sublease Total Available Asking Gross Rate Class Market Size (SF) Availability (%) Overall 8,584,812 19,847 13.5 273,974 1,428,647 16.6 32.01 (SF) (%) Available (SF) (SF) ($/PSF) Class A 3,910,378 (387,382) 41.0 683,154 2,285,803 58.5 27.60
Overall 11,550,397 (462,267) 39.5 1,129,003 5,695,183 49.3 20.78
07 | RATES & TERMS 34 Source: CBRE Research, WSJ, the banks, May 2016. 07 | RATES & TERMS 35 WTI OIL PRICE FORECAST CONSENSUS AVERAGE OF 36 INVESTMENT BANKS
WTI Price ($/BBL)
$75 $69 $70 $66 $65 $61 $60 $56 $56 $54 $55 $51 $53 $49 FORECAST: $50 $47 $49 $50 CLASS A, THE WOODLANDS AND SPRINGWOODS $45 $46 $44 $40 $41 Net Absorption (SF) Job Growth (%) • North Houston population centers $35 1,600,000 12% are some of the fastest growing in the
1,400,000 10% MSA, accelerated by the recent I-99 $30
1,200,000 completion 2017 2018 2019 2020 2021 8% »» In 2016, Conroe was the fastest- 1,000,000 6% growing U.S. city (>50,000 residents) Price Estimates 800,000 Low Mean High 4% »» Woodlands population growth has 600,000
2% averaged 3.1% over the past decade 400,000
0% 200,000 • Annual job growth in the North Houston
-2% - area has outperformed relative to RECENT LEASING ACTIVITY 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 overall the Houston MSA by an average (200,000) -4% Net Absorption, Historical Forecast Low Forecast High YoY Job Growth (1-yr lag) of 2.1% per year
Building Term Rate Starting Gross Abate Market Start Date Address Tenant Lease Type RSF OpEx TI Bumps Name (mos) Type Rate Starting (mos)
11000 Energy North 10/1/18 HP Building HP New Lease 377,000 180 NNN $25.50 $13.50 $39.00 0 $125.00 2.00% Drive
American North 10/1/18 Cityplace 2 Bureau New Lease 326,800 216 NNN $22.50 $13.50 $36.00 12 $80.00 2.00% of Shipping
460 + 480 Wildwood WDL 9/1/17 Wildwood Forest Corporate US Steel New Lease 20,000 132 NNN $16.00 $10.93 $26.93 12 $60.00 $0.50 Drive Centre
1780 Hughes Three Hughes WDL 7/1/17 Talen Energy Expansion 15,008 67 NNN $26.00 $12.60 $38.60 7 $55.00 $0.50 Landing Blvd Landing
10001 Woodloch Waterway Andrews WDL 12/1/16 New Lease 11,487 120 NNN $29.00 $13.66 $42.66 0 $25.00 3.00% Forest Dr Plaza II Kurth Llp
The Reserve at Savage NOR 7/16/17 1575 Sawdust Rd New Lease 8,278 135 NNN $19.50 $9.10 $28.60 15 $60.00 $0.50 Sierra Pines II Services
*Note that HP’s rate includes parking.
36 07 | RATES & TERMS 07 | RATES & TERMS 37 Strengths Strengths & • High quality materials • Location: At the premier corner of North Houston at Springwoods Challenges Village Parkway and I-45 • Accessibility: Gateway location with high visibility from I-45, Identify strengths and weaknesses the Hardy Toll Road and the Grand Parkway of the current design in relation to: • Easy access to major region location in the submarket, accessibility activity centers: Downtown, to public transportation, current base Energy Corridor, The Woodlands, Greenspoint, Houston building design, floor plate(s) layout Intercontinental Airport including elevators, core configuration • Energy efficient building & size, parking ratio, building amenities, • Strength of ownership • Flexibility in design to attract differentiators, etc. major users • Targeting LEED Gold certification • Signage Opportunities Perception is the lens through which we view reality Challenges • Stagnant Houston office market We are adept at creating positive market perceptions 08 • Timing and shaping new realities by understanding how • Lack of marketing center STRENGTH & occupiers evaluate and select their workspaces, which • Energy tenants in cost is a combination of both functional and emotional cutting mode experiences. Our ability to provide an objective and honest CHALLENGES • Less amenities than neighboring assessment of Spring Crossing’s strengths and challenges buildings allow us to set the most effective and direct path forward for rapid lease-up. Opportunities • Visibility and branding opportunity (building signage/identity) Our Recommendations • Cutting edge marketing AN ELEVATED • Define a clear message to VIEW BUILDING DESIGN the market • Discuss lobby ceiling height • Potential to create a suburban • Scale of conference amenity across 850k of office campus for major corporate user
BUILD MARKETING CENTER ONSITE AND/OR IN-TOWN Threats • Deliver a one-of-a-kind, • Other new construction: memorable experience Springwoods Village • Build in state-of-the-art technology • Sublease space • Energy tenants looking for aggressive economics
Phase I Lobby 38 08 | STRENGTH & CHALLENGES 08 | STRENGTH & CHALLENGES 39 Fees & References
Provide proposed brokerage fees. Capitol Tower’s expectation is that there will be fee sharing given Capitol Tower’s engagement and involvement.
Exceptional Results The measures of our success are our PLEASE INCLUDE 3-5 CURRENT CLIENTS THAT long-standing relationships, process CAN SERVE AS REFERENCE FOR THE SERVICES driven execution and consistent, YOU ARE PROPOSING TO PROVIDE. exceptional results. We are your advocate and advisor––exceeding your service expectations and your investment. We are a team JOHN GOFF that is locally invested and globally CRESCENT REAL ESTATE HOLDING connected—a combination that is Greenway Plaza | 4,300,000 sq. ft. 09 indispensable as we work together to FEES & grow Spring Crossing. REFERENCES GIORGIO BORLENGHI n INTERFIN CORPORATION Four Oaks Place | 1,750,000 sq. ft. Office fees AN ELEVATED VIEW As an extension of the 0-10 years: 2% Skanska team, CBRE will 10+ years: 1% ensure that Spring Crossing MELAYNE PACKER leads the competition with METLIFE 3040 Post Oak |426,000 sq. ft. a sense of community to FEE SHARING set world-class standards in 0-10 years: 0.5% workplace destinations. 10+ years: 0.25%
MIKE WYATT CORE REAL ESTATE 8 West Centre |200,000 sq. ft.
40 08 | FEES & REFERENCES 08 | FEES & REFERENCES 41 he measures of CBRE’s success are our long-standing relationships; our credibility and trust-worthiness in the market; our capacity and non-conflicted time T dedication; process driven execution; and consistent, exceptional results. We are your advocate and advisor— exceeding your service expectations and advancing your investment. Our project team is locally invested and globally connected—a combination that is indispensable as we work together to deliver Spring Crossing. Our value and commitment to Skanska includes:
EXPERIENCE WE’VE DONE THIS BEFORE
We know how to drive maximum momentum around your project, execute a speedy lease- up and generate measurable ROI.
ACCESS We’re WE ARE INTEGRATED EXPERTS
We provide comprehensive access to a Ready wealth of resources, collective insight and tenant opportunities.
FOCUS WE KEEP THE ENDGAME IN SHARP FOCUS
Our leasing and marketing plan calls for creativity, energy and the specialized experience required to drive value.
RESULTS WE OPERATE WITH AN OWNER’S MINDSET
Our success is tied to yours, and we are committed to achieving the best and highest results for your project.
42 08 | FEES & REFERENCES 08 | FEES & REFERENCES 43 MANAGING CONFLICTS OF INTEREST
10 APPENDIX
AN ELEVATED VIEW
44 10 | APPENDIX 10 | APPENDIX 45 MANAGING CONFLICTS OF INTEREST
Introduction CBRE has the broadest platform in our industry in both real and perceived conflicts of interest.Introduction Even when When we make decisions as to what assignments to • expects to receive a benefit from a person other terms of geography and the types of services we offer. there is no actual conflict of interest, it is possible that accept and how to manage conflicts if and when they than the client in relation to a service provided to How do we define conflicts of How do we define conflicts interest? We act in a variety of capacities for clients across the a client might be sensitive to a given situationof interest? or might arise, we will always adhere to our fiduciary duties and the client other than a market-based commission globe. For example: perceive it as a conflict. place the interests of the client we represent ahead of or fee for that service, for example in the form of a Managing Conflicts Managing Conflicts our own. To combat any short term incentives on the discount, monies, goods or services. • We represent clients as a broker in real estate We do not sell any tangible product, and daily Compliance with Law >Compliance with Law part of any individual to exploit conflicts for personal transactions depend on our reputation for service excellence as We have created an Appendix to this policy that Ability to Perform Ability to Perform gain, we have implemented policies, procedures, the foundation of our business franchise. We have lists examples of where conflicts may be expected to Clarity in our Role • We manage property at the physical site on behalf Clarity in our Role disciplinary, structural and compensatory measures, only one reputation, and yet each day thousands arise in our business. The list is not intended to be Obligation to Disclose Conflicts of clients (including the procurement of supplies and Obligation to Disclose Conflicts governance systems and training programs. We have of individuals are taking actions that may impact exhaustive and CBRE personnel must consider all Independence and Objectivity services needed to operate the property) Independence and Objectivity well-established and publicized avenues to investigate it. While, to an outsider, incentives to exploit a services and activities carried out by the firm in order Our Subsidiaries • We appraise the value of real estate for clients Our Subsidiaries concerns or allegations and, if we determine that any of particular conflict of interest for our own short-run to identify any conflicts that may arise. Confidential Information and the Confidential Information and the our personnel violate our policies, we take appropriate “Need to Know” Policy • We arrange for financing of real estate for clients gain may appear to be strong, our firm’s reputation“Need to is Know” Policy remedial actions, including disciplinary action against Managing Conflicts Information Barriers • We invest capital, our own and our clients, in real paramount and we manage our firm to createInformation long- Barriers any employee engaged in the misconduct. CBRE has established policies and procedures Outside Activities and Personal estate, directly or through loans or securities term value for our stakeholders. Therefore, exploitingOutside Activities and Personal Ownership of Property conflicts of interest—in addition to being at oddsOwnership with of Property How do we define conflicts of interest? in each of its operations to identify and manage • We service real estate mortgages, loans and conflicts of interest. These policies and procedures Gifts and Entertainment our firm’s “RISE” values of Respect, Integrity, ServiceGifts and Entertainment There is no single universally recognized definition of securitized pools are the subject of ongoing monitoring and review Research and Excellence—would be harmful to our profitabilityResearch a conflict of interest. For us, a conflict of interest arises • We publish research on real estate trends and processes embedded within our lines of businesses. Internal Policies and Training because we would have great difficulty continuingInternal to Policies and Training whenever CBRE or its employee: Escalation Procedures information sell our services. It is therefore critical for us to Escalationhave an Procedures These controls are overseen by our most senior Compliance and Monitoring Compliance and Monitoring • could make a financial gain, or avoid a financial executive officers, who are supported by our Legal and Clients often ask us to act in several of these capacities effective conflict management and business selection loss, at the expense of the client; Compliance Departments. These personnel play a vital in our overall relationship, frequently across multiple process that is overseen by experienced, senior people • has an interest in the outcome of a service provided role in the formulation of policies and make judgments geographies. Company-wide, we also act in these and embedded in the core decision-making of the to the client or of a transaction carried out on behalf regarding the appropriate resolution of particular roles for hundreds of clients simultaneously. firm. of the client, which is distinct from the client’s interest conflicts, as further described in this document. Further Information Further Information CBRE is sensitive to potential engagements that might in that outcome; CBRE will review and update this document Our size and the scale and diversity of our lines of CBRE will review and update this document be legally permissible and not technically posing Some of the standards we employ to identify and periodically as necessary. Questions business allow us to accept the largest and most periodically as necessary. Questions • represents or seeks to represent two or more parties regarding this policy should be addressed to conflicts of interests, but problematic fromregarding a client this policy should be addressed to manage conflicts are described below: complex assignments anywhere in the world. They also whose interests are actually or potentially in conflict the CBRE Chief Compliance Officer at the relations perspective. These business selectionthe CBRE issues, Chief Compliance Officer at the address herein. enable us to invest in market intelligence, research address herein. with each other; Compliance with Law Click here to view examples of conflicts and other client-facing expertise that are unrivaled if not promptly identified and properly managed,Click here tomay view examples of conflicts We comply with all laws and regulations relating to our • represents a client and CBRE has a financial or other that could arise in our business. by our competitors. They create value for our clients, lead to ill-will and a loss of business. The principlesthat could arise in our business. business. incentive to favor the interest of another client, or shareholders and other stakeholders. However, as a we employ to manage these business selection issues Contact Chief Compliance Officer Contact Chief Compliance Officer group of clients, over the interests of the client; result of our scale and diversity and the nature of the are similar to those involved in the management of CBRE is subject to a myriad of federal, state or To read our Standards of Business conflicts of interest. To read our Standards of Business • carries on the same business as the client; or province, and local laws throughout dozens of Conduct, please click here. real estate services business itself, we inevitably face Conduct, please click here.
Managing Conflicts of Interest | June 2015 |2 Managing Conflicts of Interest | June 2015 |3
46 10 | APPENDIX 10 | APPENDIX 47 MANAGING CONFLICTS OF INTEREST
Introduction countries, including real estate licensing laws in the management businesses) also utilize investmentIntroduction or to occur in the scope of an assignment.2 As part of jurisdictions where it operates. Per our Standards pricing committees to undertake a centralized review this disclosure, we will also describe other activities How do we define conflicts of How do we define conflicts of interest? of Business Conduct, compliance with the relevant for conflicts prior to accepting any assignment.interest? we may continue to perform as a business while we laws and regulations is a non-negotiable condition are representing a particular client. Disclosure of all Managing Conflicts If CBRE determines that it is unable to perform the of employment with CBRE. We have well-established Managing Conflicts conflicts is required even where we have employed requested assignment for any reason, including that Compliance with Law avenues for identifying and investigating reports of Compliance with Law other measures to manage the conflicts and those it would be unable to manage a conflict of interest >Ability to Perform violations by our personnel, and our employees know Ability to Perform measures have mitigated the risk of any damage to a using one or more of the methods described in this >Clarity in our Role that violations can lead to disciplinary action, up to Clarity in our Role client’s interests. document, it will decline to act on behalf of a client. > Obligation to Disclose Conflicts and including termination of employment. > Obligation to Disclose Conflicts In such case, CBRE’s personnel will be asked to step We recognize that conflict disclosures are typically Independence and Objectivity Independence and Objectivity Ability to Perform down from working on a specific transaction. expressed as disclaimers in engagement letters. We Our Subsidiaries Our Subsidiaries CBRE will accept only those assignments it can perform endeavor to make our disclosures meaningful, effective Confidential Information and the Clarity in our Role Confidential Information and the “Need to Know” Policy to its high standards for excellence. “Need to Know” Policy and prompt. Thus, our disclosure shall be in clear, fair CBRE will be clear about its role and responsibilities in Information Barriers Information Barriers and straight-forward language and contain sufficient Prior to accepting any assignment, we will ensure that any assignment. Outside Activities and Personal Outside Activities and Personal information to allow the client (and, if applicable, Ownership of Property we are able to perform our responsibilities to our high representation of the tenant, it will be made clear that At the outset of any assignment we accept,Ownership we of Property other parties to the transaction) to make an informed Gifts and Entertainment standard of excellence all the way through execution CBRE represents the landlord in the building and the will clearly articulate our role and our specificGifts and Entertainment decision as to whether to proceed. The disclosure Research of the transaction without compromising the client’s team assigned to advise the landlord will be different responsibilities to our client. CBRE personnelResearch are should be tailored to the specific engagement or line Internal Policies and Training or another client’s interests. This necessarily includes and segregated from the tenant’s team—with each trained to be unambiguous regarding the partyInternal Policies and Training of business and kept updated over time. Escalation Procedures identifying whether any conflicts of interest exist or are team having a fiduciary obligation only to the party represented by CBRE in any transaction andEscalation to disclose Procedures Compliance and Monitoring anticipated. In most cases, this disclosure occurs prior to accepting they represent—the tenant or the landlord. the client relationship at the earliest possibleCompliance time to all and Monitoring an assignment. For example, prior to accepting an The conflicts review process may vary by line of parties to the transaction.. Our real estate professionals are expected to escalate assignment to manage a property, we will disclose that business, country or by assignment type. For example, any questions regarding how to resolve conflicts to we might already be the primary real estate advisor this review may be conducted directly through Obligation to Disclose Conflicts their managers, who may further escalate the matter It is CBRE policy to disclose to our client all known to one or more tenants in the building. The owner of Further Information database and personal inquiries by our real estate Further Information to our geographic or line of business executives and conflicts of interest. the building will understand clearly through disclosure CBRE will review and update this document professionals and managers who are trained to identify CBRE will review and update this document ultimately to our senior executive officers. Along the that (a) CBRE will have an obligation to advise the periodically as necessary. Questions conflicts of interest. For certain types of assignments, periodically as necessary. Questions way, our Legal and Compliance Departments provide regarding this policy should be addressed to All CBRE personnel who interact with clientsregarding have this policy a should be addressed to tenant client regarding its renewal rights and options the CBRE Chief Compliance Officer at the we utilize a centralized and formal conflict check advice and counsel. responsibility to identify and disclose anythe actualCBRE Chief or Compliance Officer at the in the marketplace and (b) the team that advises address herein. procedure.1 Certain of our businesses (e.g., Global address herein. potential conflict that exists or is reasonably likely the tenant will be different and segregated from the We believe our clients are entitled to understand fully Click here to view examples of conflicts Corporate Services, Asset Services and investment Click here to view examples of conflicts that could arise in our business. that could arise in our business. landlord’s team. Conversely, prior to accepting the the nature, amount and timing of compensation that
Contact Chief Compliance Officer Contact Chief Compliance Officer
To read our Standards of Business To read our Standards of Business Conduct, please click here. 1. For example, where the transaction contains a higher level of risk or regulations apply (e.g., government contracts, insolvency-related assignments), we 2. This disclosure will omit certain facts that could technically qualify as conflicts but are so inherent and self-evident in the real estate business model; for will utilize internal databases and/or e-mail confirmation of relevant CBRE personnel. Conduct, please click here. example the fact that the landlord in a lease transaction will typically pay the commissions of both its broker and the tenant’s broker or the fact that the tenant’s broker’s commission is typically based on total rental value (i.e., term multiplied by rate).
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48 10 | APPENDIX 10 | APPENDIX 49 MANAGING CONFLICTS OF INTEREST
Introduction CBRE anticipates receiving for our services, even when • any financial interest of CBRE in any thirdIntroduction party or disadvantage them in the market nor ask them to of its clients to whom it owes fiduciary duties. For it is contingent or not entirely paid directly by our client property; or yield to the pressure brought to bear by another example, a CBRE Global Investors sponsored fund How do we define conflicts of How do we define conflicts of 3 interest? (e.g., a tenant representation brokerage commission • any agreement or transaction which hasinterest? been, will firm client in a competitive situation. This is for two could be in litigation with a CBRE client regarding paid by the landlord). Thus, our explanation of the or may be, entered into by CBRE. important reasons. First, because these subsidiaries the sale of a property. In this instance, CBRE Managing Conflicts compensation we anticipate should be complete and Managing Conflicts act as fiduciaries for their own investor clients, it employees or executives must recuse themselves from The above examples are not exhaustive, and CBRE Compliance with Law easy to understand. Where an amount is not possible Compliance with Law would be inappropriate to disadvantage them due any communication with either party regarding the and its employees are required at all times to consider Ability to Perform to calculate at the outset of an assignment, we will Ability to Perform to a relationship with a firm client that would benefit dispute. As such, a CBRE employee must decline any the need to act independently of any conflicting Clarity in our Role share the formula on which expected compensation Clarity in our Role only the parent.4 Second, CBRE Global Investors and requests from a CBRE client to intervene in, mediate interest. Obligation to Disclose Conflicts will be derived. The nature of our legal duties prohibits Obligation to Disclose Conflicts Trammell Crow Development Services are among or influence any such disputes, even when such client >Independence and Objectivity CBRE or its personnel from receiving any “secret Our Subsidiaries Independence and Objectivity CBRE’s largest clients in their own right. For example, threatens a business consequence against CBRE. >Our Subsidiaries profit” or benefit in addition to the fee payable when a CBRE’s subsidiaries operate with appropriate>Our Subsidiaries acting as a fiduciary for its investor clients, CBRE Our subsidiaries operate with independence from Confidential Information and the transaction is successfully completed. In this vein, when independence from our other business lines andConfidential we Information and the Global Investors will often hire CBRE to manage “Need to Know” Policy “Need to Know” Policy the other parts of our business. Subsidiary personnel it manages a client’s properties, projects or facilities, do not give them any improper advantage over other buildings it acquires or to market those properties for Information Barriers Information Barriers report to management within the subsidiary, are CBRE will often procure goods or services (including CBRE clients. leasing or sale. It demands a fair price, the highest not integrated within office space with other CBRE Outside Activities and Personal hiring subcontractors) on behalf of its clients and, in Outside Activities and Personal level of service and access to market intelligence and Ownership of Property Ownership of Property employees and are compensated based on the success doing so, may use its purchasing power and aggregate Certain of CBRE’s subsidiaries, including CBRE Global opportunities from CBRE as it does all of its other large Gifts and Entertainment Gifts and Entertainment of their subsidiary or business unit only. To preserve those purchases with its own. Typically, this results in Investors and Trammell Crow Development Services, service providers. Thus, CBRE will neither favor nor Research Research independence, there is no internal compensation or our client receiving more favorable than “market” are active participants in many of the most competitive disadvantage its own or its subsidiaries’ interests when Internal Policies and Training Internal Policies and Training incentive, rebate or any other benefit to induce our pricing due to CBRE’s purchasing power or scale. markets in which we provide services. As stated engaged to provide services to any client. Escalation Procedures Escalation Procedures subsidiaries to select CBRE as their service provider.5 However, if CBRE will receive any material business elsewhere in this document, when we are engaged Compliance and Monitoring Compliance and Monitoring benefit from the vendor as a result of those purchases, to market a property on behalf of a client, having an There may also be situations where the legal or While we encourage strong lines of communication the benefit to CBRE will be disclosed to the client. ownership or other financial interest in a prospective business interests of a subsidiary or a subsidiary’s and good relations among these businesses, we also purchaser or developer is a conflict of interest. client, on the one hand, and a CBRE client, on the strive to develop similarly strong relationships with our Independence and Objectivity Similarly, when we represent a prospective tenant or other hand, conflict (including potential litigation). other clients. Further Information When we provide services to our clients, CBRE purchaser and a subsidiary owns the subjectFurther property, Information In such instances, our subsidiary must maintain CBRE will review and update this document personnel will disclose the existence of any of the a conflict of interest exists. It is our policyCBRE that will wereview will and update this document independence and act solely in the best interests periodically as necessary. Questions following interests and must not allow the existence periodically as necessary. Questions regarding this policy should be addressed to disclose our intercompany relationships regardingand they this will policy should be addressed to the CBRE Chief Compliance Officer at the of such interests to influence them when dealing with be disregarded when we make recommendationsthe CBRE Chief or Compliance Officer at the address herein. clients or potential clients: address herein. 3. It is not unreasonable for a market participant (who might be a CBRE client) that is competing for a property being marketed by CBRE’s brokers to be arrange transactions with or for our clients. upset if a CBRE subsidiary submits the winning bid. However, in striving for fundamental fairness and in discharging our duty to the seller, CBRE does not Click here to view examples of conflicts Click here to view examples of conflicts engage in favoritism for the benefit of its Subsidiary. that could arise in our business. • any personal interests which our personnel or When they seek opportunities in the market,that could our arise in our business. members of their family may have in any third party, 4. CBRE Global Investors puts the interests of its own clients ahead of its own or CBRE’s interest. It has adopted a policy regarding transactions with CBRE subsidiaries sometimes find themselves in competition and other subsidiaries. Under this policy, CBRE is required to compete with other service providers on the basis of its ability to provide market intelligence, Contact Chief Compliance Officer property or transaction; Contact Chief Compliance Officer transactional excellence and a fair price. with some of CBRE’s most valued clients. And while To read our Standards of Business • any existing or prospective business relationship CBRE will not provide an improper advantageTo read inour Standards of Business 5. The only exception is that our Trammell Crow Development Services business will receive a discount from the commission charged by CBRE’s brokerage Conduct, please click here. Conduct, please click here. line of business when it selects CBRE versus a CBRE competitor (although our competitors are free to offer their own discounted rates), or when the between CBRE and any third party; any transaction to its subsidiaries, neither will it assignment is awarded to CBRE on a non-compete basis.
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50 10 | APPENDIX 10 | APPENDIX 51 MANAGING CONFLICTS OF INTEREST
Introduction Confidential Information and the Introduction Under our information barrier policies, if a client or business of the firm and to avoid activities that might “Need to Know” Policy one of our real estate professionals or managers interfere or conflict with, or appear to interfere or How do we define conflicts of How do we define conflicts of interest? CBRE has effective procedures in place to protect interest? determines that an information barrier is required, a conflict with, the employee’s responsibilities to CBRE confidential information entrusted to us and to control team is created to act for the client that includes no and its clients. Approval is required before our Managing Conflicts the flow of such information within the firm. Managing Conflicts employee who has performed work for, or otherwise employees may engage in outside employment, board Compliance with Law Compliance with Law is exposed to the confidential information of, any memberships or business activities within our industry. We know a great deal about our clients and their Ability to Perform Ability to Perform other party to the transaction who is represented by Such requests are approved only after a review of trust in us is the foundation of our brand and our Clarity in our Role Clarity in our Role CBRE. A responsible manager informs each team potential conflicts and if the outside activity does not ongoing business success. Earning and maintaining Obligation to Disclose Conflicts Obligation to Disclose Conflicts member about this procedure and requires a specific present a substantial risk of confusing clients or others that trust requires that we handle others’ confidential Independence and Objectivity Independence and Objectivity acknowledgement of the duty of confidentiality. as to the capacity in which the employee is acting. information at least as carefully as we would our own. Our Subsidiaries Our Subsidiaries The manager has discretion to adopt certain other The mishandling of that information could hurt our A conflict of interest arises if CBRE, its personnel or > Confidential Information Confidential Information and the procedures that are designed to enhance information a subsidiary has an ownership interest in a property and the “Need to Know” Policy client or other parties. In addition, acceptance of client “Need to Know” Policy security, including by way of example: physical under consideration by a buyer, tenant or seller, or in a >Information Barriers confidential information creates a legal responsibility Information Barriers separation of the client team and their staff, securing competing property. In virtually every jurisdiction where Outside Activities and Personal on our part to protect it and mishandling it could >Outside Activities and Personal of files and offices, and/or establishment of a code Ownership of Property Ownership of Property we operate, real estate regulations require that a real have severe consequences. For these reasons, we name in place of each client’s actual name. The Gifts and Entertainment Gifts and Entertainment estate professional who is involved in a transaction have adopted a policy that all non-public information manager monitors the teams and the situation on an Research Research with a property in which they have an ownership obtained from a client or potential client shall be ongoing basis to assess the continuing effectiveness Internal Policies and Training Internal Policies and Training interest must disclose their ownership interest to all treated as confidential and shall not be shared outside Information Barriers of the information barrier and make adjustments as Escalation Procedures Escalation Procedures parties involved in a transaction involving that property. CBRE unless explicitly permitted by the terms of a Information Barriers effectively segregate sensitive necessary. Compliance and Monitoring Compliance and Monitoring confidentiality agreement or required by the terms information within the firm. And, in certain of our business lines and geographies, of a transaction or relevant law or regulation. We In the event CBRE determines that a client’s there is an outright prohibition on performing services have designed IT systems to reinforce this policy in Sometimes, we or our client determines that a policy confidentiality is compromised, it will notify the client, for a client while having such ownership interests. the reality of a 21st century where most information is or agreement regarding confidentiality should be and any employee found to have violated his or her Our policies typically permit our personnel to enjoy Further Information communicated digitally. We periodically require our supplemented by more formal barriers toFurther impede Information obligations will be subject to disciplinary action, up to the investment benefits derived from ownership of CBRE will review and update this document personnel to certify their acceptance of this important or prohibit the flow of information withinCBRE the will firm. review and update this document termination of employment. real estate but at the same time require disclosure periodically as necessary. Questions policy and provide training regarding its requirements. An “information barrier” is a set of proceduresperiodically as necessary. Questions to the firm of certain types of commercial real estate regarding this policy should be addressed to regarding this policy should be addressed to designed to segregate information and prevent the Outside Activities and Personal Ownership of investments such that the firm can properly disclose the CBRE Chief Compliance Officer at the Internally, CBRE operates on a “need to know” basis. the CBRE Chief Compliance Officer at the Property address herein. communication of that information by personneladdress herein. in these interests. Our policies also contain provisions That is, confidential information may be disclosed only We have adopted appropriate controls to monitor and Click here to view examples of conflicts one part of CBRE’ business with employeesClick inhere another to view examples of conflicts that specify how these conflicts of interest are to be that could arise in our business. to those persons who need it to serve the legitimate part of CBRE. These procedures not onlythat make could arisethe in our business. disclose the outside business or financial interests of managed. interests of clients and who can be expected to keep it transfer of information less likely but can also reduce our employees. Contact Chief Compliance Officer in confidence. Contact Chief Compliance Officer CBRE does not permit its employees to acquire, hold the appearance of conflicts of interest. Unless otherwise approved, CBRE employees are To read our Standards of Business To read our Standards of Business or otherwise trade in securities in our clients when they Conduct, please click here. Conduct, please click here. required to devote their full time and efforts to the have access to material non-public information about
Managing Conflicts of Interest | June 2015 |8 Managing Conflicts of Interest | June 2015 |9
52 10 | APPENDIX 10 | APPENDIX 53 MANAGING CONFLICTS OF INTEREST
Introduction the client. In certain of our businesses, we maintain themselves. There is a line between theseIntroduction customary Internal Policies and Training their span of control to ensure that any new conflicts of and enforce a formal restricted securities list. In the gifts and the types of gifts or entertainment that are How do we define conflicts of CBRE has training and communication tools to help interest or business selection issues that may arise are remainder, we rely on the compliance with our policies perceived to be excessive. We do not permitHow do our we define conflicts of interest? interest? professionals identify and manage conflicts. documented and effective controls are put in place to and law and the informed judgment of our personnel. employees to give a gift knowing that the recipient manage them. They are at all times supported by the Managing Conflicts would be in violation of his/her company’sManaging own Conflicts A proper understanding and awareness of agency firm’s Legal and Compliance Departments and other Gifts and Entertainment principles, fiduciary responsibilities and CBRE policies Compliance with Law policies. We similarly do not permit our employeesCompliance with Law subject matter experts. CBRE has adopted policies relating to the giving and will maximize the likelihood that we will avoid even the Ability to Perform to accept any gift or entertainment that couldAbility be to Perform receiving of business gifts and entertainment. appearance of impropriety and enhance our ability to Compliance and Monitoring Clarity in our Role perceived to improperly influence CBRE’s Claritybusiness, in our Role effectively identify and manage conflicts of interest and CBRE has effective compliance systems to address Obligation to Disclose Conflicts Appropriate entertainment of clients has always purchasing choices or decisions on behalf Obligationof any to Disclose Conflicts business selection issues. CBRE has developed training concerns regarding conflict and business selection Independence and Objectivity been a normal part of our business and we believe client. In certain sensitive areas of our businessIndependence and Objectivity programs and other communication tools on these issues. Our Subsidiaries it provides opportunities to build relationships with (primarily dealing with procurement), we prohibitOur Subsidiaries topics that are made available to our professionals Confidential Information and the clients. However, employees are always expected to the giving or receiving of anything of value.Confidential Where Information and the We have established avenues for our clients or other “Need to Know” Policy “Need to Know” Policy and managers. Training and internal guidance are use common sense when making decisions related not outright prohibited, CBRE has implemented third parties to report to us any circumstance in which Information Barriers Information Barriers used to help our personnel identify circumstances to business entertainment and must bear in mind that certain guidelines that clarify the nature of any gift or they believe a conflict of interest was not disclosed Outside Activities and Personal entertainment that our employees may acceptOutside without Activities and Personal which may give rise to potential conflicts of interest Ownership of Property their actions at all times reflect on CBRE as well as Ownership of Property or managed in a manner consistent with our own specific high levels of executive approval, and has and business selection issues and provide them with >Gifts and Entertainment Gifts and Entertainment policies or the law. Each report received from a required that certain gifts and/or entertainment be the necessary tools to manage any such issues. >Research Research client or prospective client will be escalated to the disclosed and/or approved by senior management. Internal Policies and Training >Internal Policies and Training Escalation Procedures appropriate personnel within CBRE to be addressed. Escalation Procedures Research >Escalation Procedures CBRE has established an effective escalation process Typically, allegations of this nature will be treated Compliance and Monitoring CBRE’s research is objective and impartial.>Compliance and Monitoring for resolving conflicts and business selection issues. as reports of serious misconduct under our Ethics and Compliance Program. This requires that they be CBRE prepares and issues real estate market and Our first line managers are trained and authorized promptly, thoroughly and impartially investigated under investment research relied upon by many institutional to resolve business practice and conflicts issues that the supervision of our Chief Compliance Officer. If real estate investors to allocate their resources and arise at the regional and business line levels including a violation is found, prompt and thorough remedial Further Information Further Information investments. As such, it is critical that all research which assignments we will accept or decline. Our action will be taken. CBRE will review and update this document CBRE will review and update this document real estate professionals are trained to escalate produced by CBRE be objective, impartial, fair and periodically as necessary. Questions periodically as necessary. Questions difficult conflicts issues to their managers. Based on Our Chief Compliance Officer will have responsibility regarding this policy should be addressed to not misleading. CBRE has implementedregarding policies this and policy should be addressed to the CBRE Chief Compliance Officer at the the CBRE Chief Compliance Officer at the their training and knowledge of CBRE policy, our for the subject matter of this document and for procedures to identify, disclose and manage conflicts address herein. address herein. managers might escalate the issue to a more senior annually reviewing, developing and strengthening our of interest that may arise in the preparation and Click here to view examples of conflicts Click here to view examples of conflicts level of management or involve members of our Legal policies and procedures relating to managing conflicts. that could arise in our business. distribution of our research and to ensurethat couldthat ariseour in our business. Department. Ultimately, our most senior executive A periodic review of conflicts of interest is included researchers are not subject to influence by any real Contact Chief Compliance Officer officers have authority to resolve all conflicts and in the CBRE Ethics and Compliance Program’s Contact Chief Compliance Officer estate professional who might have a stake, however business selection issues. These executives have an monitoring and audit plans, supported by our Internal To read our Standards of Business indirect, in their findings. To read our Standards of Business Conduct, please click here. Conduct, please click here. ongoing obligation to monitor the businesses within Audit Department.
Managing Conflicts of Interest | June 2015 |10 Managing Conflicts of Interest | June 2015 |11
54 10 | APPENDIX 10 | APPENDIX 55 STANDARDS OF BUSINESS CONDUCT
CBRE BOARD OF DIRECTORS From The Board Of Directors From the Board of Directors
Richard C. Blum A Message From Our CEO In 2004, we adopted our Standards of Business Director Conduct as the highest policy of the Company. While Introduction these standards have been refreshed in 2011 to Conduct Relating To Each Other reflect the way CBRE and the business environment Brandon B. Boze Director Conduct Relating To Our have evolved, the core ethical foundation of CBRE Business Partners, Clients And remains robust and our stalwart support for the Ethics Competitors and Compliance Program continues to be one of our Curtis F. Feeny primary responsibilities as a Board. Conduct Relating To CBRE’s Director Resources It has taken generations for CBRE to achieve Conduct Relating To Our our preeminent position in the global real estate Bradford M. Freeman Communities marketplace. Our success is the result of many Director Conclusion things—the knowledge, experience and extraordinary talent of our employees; the wisdom of our strategy; the quality of our services; and, above all, our high Michael Kantor standards of professionalism and business conduct. Director In the broader business community, we’ve seen many times how quickly ethical failure can cripple Frederic V. Malek a successful company—even those whose industry Director leadership was believed to be unassailable. Thus, we must remain consistently vigilant and proactive about enforcing our standards of conduct. Robert E. Sulentic Director We are requiring that everyone who represents CBRE read, understand and adhere to our Standards of Laura D. Tyson Business Conduct. You should expect no less from your Director colleagues, your senior management and us. Each of us is personally responsible for maintaining the highest standards of business conduct to ensure we continue Gary L. Wilson Director Who should I contact for to differentiate ourselves as the Company that global help? You may contact Senior clients trust with their real estate strategies. Management or one of the We appreciate your support. Ray Wirta following: Chief Compliance Chairman Officer • CBRE Ethics HelpLine: 800.799.6523 • Human Resources • Legal CBRE Standards of Business Conduct 2
From The Board Of Directors
A Message From Our CEO
Introduction
Conduct Relating To Each Other
Conduct Relating To Our Business Partners, Clients And Competitors
Conduct Relating To CBRE’s Resources CBRE is the global leader in commercial real estate services and investment. We are home to the world’s most Conduct Relating To Our Communities talented, dedicated real estate professionals, backed by the power of the industry’s strongest brand, the most compelling product offering and broadest geographic coverage. Conclusion We strive to lead in all aspects of our business. It’s what our clients expect of us, and it’s what we expect of each other. Our RISE values of Respect, Integrity, Service and Excellence are a testament to these aspirations. Our Standards of Business Conduct (“SOBC”) is a guidepost for setting all company policies and for making difficult decisions.
I take comfort in knowing that our people embrace these standards as we carry out our business activities. Thank you for your commitment to CBRE and to our shared values.
Sincerely,
Chief Executive Officer
Who should I contact for help? You may contact Senior Management or one of the following: Chief Compliance Officer • CBRE Ethics HelpLine: 800.799.6523 • Human Resources • Legal CBRE Standards of Business Conduct 3
56 10 | APPENDIX 10 | APPENDIX 57 STANDARDS OF BUSINESS CONDUCT 2015
From The Board Of Directors CBRE is firmly committed to conducting business with the highest integrity and in compliance with the letter and A Message From Our CEO spirit of the law. We are operating in a world where the This document is also available in the following languages: Introduction rules that govern business conduct are more complex >RISE Values and demanding than ever. Violating them could have >What Is The SOBC? very serious consequences to CBRE and you. • English • Hungarian What It’s Not cornerstone of our business philosophy. Our leaders RISE Values Application to All of Us, around the globe know that implementing these values • Japanese • Italian RISE: Respect, Integrity, Service, and Excellence. It’s Worldwide consistently in 60 countries globally is a challenge, pretty amazing how just four words can say so much. • Chinese – Simplified • Latvian Your Personal Commitment to especially when viewed through the lens of local Do the Right Thing But that is the power of values. They don’t have to be cultures and business practices. Conduct that appears • Chinese – Traditional • Lithuanian Special Responsibility of complicated. They don’t even need to be unique. They Managers appropriate from one culture’s perspective might be only need to be true. • Korean • Polish Who Should I Contact for Help? perceived differently from another’s. However, through The CBRE Ethics Helpline Our corporate values are the foundation upon which good economic times as well as bad, the surest path • Czech • Portuguese (Brazilian) Zero Tolerance for Retaliation our company is built. These values are timeless and to leadership and growth is remaining true to our RISE Investigation of Reports transcend all markets, service lines, languages and values. Each of us needs to believe in these values. They • Danish • Portuguese (traditional) CBRE’s Ethics and Compliance business cultures. should guide all of our actions and interactions, every Program • Dutch • Romanian day. Our future success will be determined in no small Compliance with the Law RESPECT part by the commitment we make to living these values. • Finnish • Russian Conduct Relating To Each Other To treat everyone with dignity, value their contributions, and help one another succeed. What is the SOBC? • French • Slovakian Conduct Relating To Our The SOBC embodies the fundamental principles Business Partners, Clients And INTEGRITY that govern our ethical and legal obligations. They Competitors • French Canadian • Spanish To uphold the highest standards of truthfulness and describe, summarize and implement policies, some of Conduct Relating To CBRE’s reliability in our business practices. which have been in place at CBRE for many years. We • German • Swedish Resources have organized the SOBC into four general categories SERVICE that encapsulate how we accomplish our activities on Conduct Relating To Our To dedicate ourselves to making a meaningful impact Communities a daily basis: with our clients and in our communities. Conclusion • Conduct Relating to Each Other EXCELLENCE To aspire to be the best in everything we do and drive • Conduct Relating to Our Business Partners, Clients Who should I contact for and Competitors help? You may contact Senior for continuous improvement. Management or one of the • Conduct Relating to CBRE’s Resources Maintaining a culture where our RISE values are following: Chief Compliance • Conduct Relating to Our Communities Officer • CBRE Ethics HelpLine: acknowledged and adopted universally is the 800.799.6523 • Human Resources • Legal CBRE Standards of Business Conduct 6
CBRE Standards of Business Conduct 4
From The Board Of Directors From The Board Of Directors Within each of the four categories, you will find employees have asked regarding these policies. We policy sections. Within each section, you will find hope these Learning Aids will be helpful in making the A Message From Our CEO A Message From Our CEO text explanations and resources for seeking further SOBC and the topics within “come to life.” Throughout Introduction Introduction information, including Company policies applicable the online format, you will also find important contacts RISE Values RISE Values to that section, either globally applicable or specific and an explanation of avenues for reporting concerns What Is The SOBC? >What Is The SOBC? to your location. Where a policy covers a topic within or asking questions. What It’s Not >What It’s Not this guide, we have provided a live link. In each Application to All of Us, What It’s Not Application to All of Us, section we have also provided easy-to-use Learning Worldwide Worldwide Aids and a place for you to provide us feedback. No standards of conduct, however detailed, can Your Personal Commitment to possibly anticipate all of the situations or challenges Do the Right Thing Your Personal Commitment to We created the Learning Aids based on real-world Do the Right Thing we might face on the job. The SOBC serves as a Special Responsibility of situations involving the policies or questions that our Managers Special Responsibility of roadmap and is not intended to be an exhaustive Managers Who Should I Contact for Help? description of CBRE’s policies or the law. In addition Who Should I Contact for Help? The CBRE Ethics Helpline to these standards, all employees are subject to other The CBRE Ethics Helpline Zero Tolerance for Retaliation CBRE policies that, depending on your position or Zero Tolerance for Retaliation Investigation of Reports location, are incorporated into your terms or contract Investigation of Reports CBRE’s Ethics and Compliance of employment or our employee handbook or manual. Program CBRE’s Ethics and Compliance Program Compliance with the Law If your questions are not fully addressed by these Compliance with the Law Conduct Relating To Each Other resources, your next step should be to discuss it Conduct Relating To Each Other with your supervisor or manager. Other resources Conduct Relating To Our Business Partners, Clients And Conduct Relating To Our are also available—including professionals in the Competitors Business Partners, Clients And Legal, Compliance, Finance and Human Resources Competitors Departments and the CBRE Ethics HelpLine. Conduct Relating To CBRE’s Resources Conduct Relating To CBRE’s Resources Conduct Relating To Our Communities Conduct Relating To Our The SOBC is an expression of our RISE values and represents a framework for decision-making. To this end, our Communities employees are responsible for understanding the SOBC and acting in accordance with it. The SOBC cannot and is Conclusion not intended to cover every applicable law, rule or regulation or provide answers to all questions that may arise. For Conclusion that, we must ultimately rely on each employee’s good sense of what’s right, including a sense of when it is proper to Who should I contact for seek guidance from others with respect to the proper course of conduct. The SOBC does not in any way constitute an help? You may contact Senior Who should I contact for employment contract or assurance of continued employment. It is for the sole and exclusive benefit of CBRE and may Management or one of the Introduction help? You may contact Senior 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. following: Chief Compliance Management or one of the Officer • CBRE Ethics HelpLine: following: Chief Compliance 800.799.6523 • Human Officer • CBRE Ethics HelpLine: Resources • Legal CBRE Standards of Business Conduct 5 800.799.6523 • Human Resources • Legal CBRE Standards of Business Conduct 7
58 10 | APPENDIX 10 | APPENDIX 59 STANDARDS OF BUSINESS CONDUCT 2015
From The Board Of Directors Application to All of Us, Worldwide own conduct. The SOBC represents a non-negotiable From The Board Of Directors termination, suspension, demotion or reduction in rectify a problem that already occurred, and reduce the commitment to “do the right thing” when acting on compensation). Any employees attempting to engage likelihood of its reoccurrence. A Message From Our CEO The SOBC applies to our personnel, board members A Message From Our CEO and other people acting on our behalf. Each of us has behalf of CBRE. By being part of CBRE, you are in retaliatory action will be subject to disciplinary Introduction a personal responsibility to understand these policies making a personal commitment to understand the Introduction action, up to and including termination. If you suspect CBRE’s Ethics and Compliance Program The SOBC is the centerpiece of a global initiative RISE Values and practice them in our daily business lives. policies and laws that apply to your job—and to RISE Values that you or someone else has been retaliated against called the Ethics and Compliance Program. The What Is The SOBC? always follow them. We reinforce this commitment What Is The SOBC? for raising any legal or business conduct issue, As a global company, we recognize that the specific Program was adopted by our Board of Directors in What It’s Not annually through mandatory employee certifications. What It’s Not immediately contact us through one of the avenues rules governing our conduct will vary from region- 2004, and the Board maintains active oversight over >Application to All of Us, If you have joined CBRE, made this commitment Application to All of Us, we have made available on the left-hand side of each Worldwide to-region and country-to-country. However, our RISE and fail to keep it, you put yourself, your co-workers Worldwide page of the SOBC. its implementation and operation. Our Ethics and >Your Personal Commitment values transcend these variances and apply to all of and CBRE at risk. You will be subject to disciplinary Your Personal Commitment to Compliance Program is designed to reinforce our RISE to Do the Right Thing Do the Right Thing us globally. For example, the obligation to respect action, up to and including termination, and possibly Investigation of Reports values—Respect, Integrity, Service and Excellence— >Special Responsibility of our colleagues or to act with unwavering integrity Special Responsibility of If a report regarding violation of policy or law is and ensure compliance with Company policies, and Managers legal consequences. Managers does not end once you cross a national border. received, it will be investigated and documented the laws and regulations that apply to us globally. The Who Should I Contact for Help? Who Should I Contact for Help? The SOBC has been designed to be as “globally Additionally, we cannot live up to these standards in accordance with CBRE’s approved investigation Program is designed to accomplish four objectives: The CBRE Ethics Helpline The CBRE Ethics Helpline inclusive” as practicable, and it has been customized, if we, as individuals, fail to raise concerns when we procedures. Once an allegation of serious misconduct Zero Tolerance for Retaliation >Zero Tolerance for Retaliation • Mitigate the risk of potential compliance failures translated and implemented in each country in should. That is why, in addition to knowing the legal is logged into our system, we will conduct a prompt, Investigation of Reports >Investigation of Reports which we operate. The business units and regions and ethical requirements that apply to your job, it is thorough, consistent and unbiased investigation. • Minimize the consequences of compliance failures CBRE’s Ethics and Compliance >CBRE’s Ethics and Program may, however, adopt policies and procedures that part of your responsibilities to bring issues forward if: Compliance Program These investigations are conducted by appropriate • Identify and correct compliance deficiencies are more specific or restrictive than those contained internal personnel or outside experts who will work Compliance with the Law • You are unsure about the proper course of action Compliance with the Law • Foster enterprise-wide ethics and compliance within the SOBC. If there is a conflict between a local in conjunction with the Compliance Department. accountability. Conduct Relating To Each Other and need advice; Conduct Relating To Each Other law or regulation and the SOBC, the local law or Employees are not permitted to conduct their own • You believe that someone acting on behalf of CBRE The elements of our Ethics and Compliance Program are: Conduct Relating To Our regulation would take precedence. Conduct Relating To Our investigation into the matter without permission from is doing—or may be about to do—something that Business Partners, Clients And Business Partners, Clients And the Legal department. CBRE personnel are expected to • Senior-executive ownership and Board oversight Competitors Anyone who engages vendors, consultants or violates our values or the law; or, Competitors provide full cooperation and truthful, complete answers • Standards and policies temporaries on our behalf is responsible for monitoring • You believe you may have been involved in Conduct Relating To CBRE’s Conduct Relating To CBRE’s in an investigation, and failure to do so will result in such persons’ work to ensure they act in a manner any misconduct. • Communication Resources Resources disciplinary actions, up to and including termination. consistent with the SOBC. If you need guidance in this Special Responsibility of Managers • Training Conduct Relating To Our Conduct Relating To Our We will, where practicable and permissible, endeavor area, you should contact your supervisor or manager, • Monitoring and auditing Communities If you are a manager, you have special trust and Communities to keep the person reporting the issue apprised of the or a member of the Legal, Compliance or Human responsibilities under the SOBC. Our managers have progress and outcome of the investigation. Consistency • Whistleblower Program with multiple avenues for Conclusion Resources Departments. Conclusion a great deal of influence over CBRE’s values and of process and outcomes in investigation is achieved reporting violations culture. Managers are expected to embody our RISE Who should I contact for Your Personal Commitment by requiring our investigators to attend annual training • Investigation of suspected misconduct values, set an example with their own conduct and act Who should I contact for help? You may contact Senior to Do the Right Thing help? You may contact Senior and regular case peer-review meetings. If corrective • Enforcement of standards and policies through promptly when they become aware of something that Management or one of the Each person at CBRE is responsible for his or her Management or one of the action is required as a result of the investigation, we will discipline and incentives violates the SOBC, other policies or law. following: Chief Compliance following: Chief Compliance determine the appropriate steps to take (including, when • Ongoing risk assessments and continuous Officer • CBRE Ethics HelpLine: Officer • CBRE Ethics HelpLine: appropriate, legal action) to stop the ongoing violation, improvement 800.799.6523 • Human 800.799.6523 • Human Resources • Legal CBRE Standards of Business Conduct 8 Resources • Legal CBRE Standards of Business Conduct 10
From The Board Of Directors Who Should I Contact for Help? From The Board Of Directors The Program is administered by our Chief Compliance LEARN MORE ABOUT THE RISE VALUES, COMMITMENT TO DO THE RIGHT THING, AND If you have a question or concern about an ethical or Officer. The Chief Compliance Officer makes A Message From Our CEO A Message From Our CEO SPECIAL RESPONSIBILITY OF MANAGERS compliance-related issue, you have multiple options. regular reports to the Board of Directors regarding Introduction Your supervisor or manager is usually a good place to Introduction the operation and effectiveness of the Program. The RISE Values start. You may also get help and advice from: RISE Values Chief Compliance Officer works closely with our legal professionals, senior officers and other personnel What Is The SOBC? • Any member of your management team; What Is The SOBC? What It’s Not What It’s Not involved in relevant areas at each of our business • Any member of the Human Resources, Compliance, Application to All of Us, Application to All of Us, units. The Chief Compliance Officer also establishes Worldwide or Legal Departments; Worldwide the standards for the ethics and compliance programs Your Personal Commitment to • The Chief Compliance Officer – ChiefCompliance@ Your Personal Commitment to that will be implemented in each country and region in Do the Right Thing Do the Right Thing cbre.com; or, which we operate worldwide. Special Responsibility of Special Responsibility of Managers • The CBRE HelpLine – (800) 799-6523 (see below) Managers Compliance with the Law >Who Should I Contact for Your business unit or region may establish additional Who Should I Contact for Help? Help? tolerance policy for retaliation for raising a concern No excuse or pressure justifies breaking the law or avenues of reporting issues or concerns. The CBRE Ethics Helpline >The CBRE Ethics Helpline under the SOBC.) The call summary is then forwarded encouraging someone else to do so. Wherever CBRE has Zero Tolerance for Retaliation >Zero Tolerance for Retaliation to a Compliance Officer to follow up on the matter. an internal policy that is stricter than what is required by The most important thing is that you raise the concern Investigation of Reports Investigation of Reports We will attempt to respond to your call very quickly, local law, you are expected to follow CBRE’s standard. quickly and effectively. >CBRE’s Ethics and CBRE’s Ethics and Compliance particularly when the nature of the concern makes Compliance Program In providing real estate services, local laws govern Program The CBRE Ethics Helpline speed important. If an investigation is undertaken, we >Compliance with the Law almost all aspects of our business activities. Violation of Compliance with the Law We have provided a confidential and anonymous will look into the issue promptly and, whenever called Conduct Relating To Each Other local licensing laws could subject you, your colleagues Conduct Relating To Each Other method for you to ask questions and raise concerns for, see that corrective action is taken. about our SOBC—the CBRE HelpLine. The CBRE Conduct Relating To Our and CBRE to possible fines, sanctions and loss of the Conduct Relating To Our Business Partners, Clients And ability to maintain a real estate license. It is imperative Policy Guidance HelpLine is always available if you are uncomfortable Zero Tolerance for Retaliation • Standards of Conduct Business Partners, Clients And Competitors that you consult the Legal Department if you are unsure Competitors using one of the other resources identified in the If you seek advice, raise a concern or report • Non-Retaliation SOBC, or if you are not satisfied with the response you misconduct, you are doing the right thing. The Conduct Relating To CBRE’s about a potential course of action when navigating the Conduct Relating To CBRE’s have received from them. commitment to our RISE values includes providing an Resources often confusing area of compliance with the license Resources opportunity for employees to express their concerns requirements in your country or state. The CBRE HelpLine is operated 24/7 by an Conduct Relating To Our Conduct Relating To Our and report misconduct without fear of retaliation. Communities Communities independent company. When you call the CBRE Therefore, you will never face retaliation for raising HelpLine, a trained specialist will speak to you and Conclusion Conclusion a concern, reporting a violation or participating prepare a summary of your call. If you choose to in an investigation. Retaliation is usually defined Who should I contact for remain anonymous, the report will not identify you. (Of as an “adverse employment action” or any action Who should I contact for help? You may contact Senior course, giving your name can often help us investigate help? You may contact Senior Management or one of the affecting the terms or conditions of employment (e.g., the matter, and as explained below, CBRE has a zero Management or one of the following: Chief Compliance following: Chief Compliance Officer • CBRE Ethics HelpLine: Officer • CBRE Ethics HelpLine: 800.799.6523 • Human 800.799.6523 • Human Resources • Legal CBRE Standards of Business Conduct 9 Resources • Legal CBRE Standards of Business Conduct 11
60 10 | APPENDIX 10 | APPENDIX 61 STANDARDS OF BUSINESS CONDUCT 2015
From The Board Of Directors From The Board Of Directors Preventing Harassment Would it embarrass you or CBRE if your conduct were videotaped and reported on the evening news? A Message From Our CEO A Message From Our CEO When someone is subjected to inappropriate conduct that interferes with his or her ability to do and enjoy Introduction If you manage or supervise other employees, it is your Introduction their job, we all suffer. The Company has implemented job to enforce CBRE’s policies. If inappropriate conduct Conduct Relating To Each Other strong policies against harassment in each country where Conduct Relating To Each Other such as harassment occurs on your watch and you do Providing Equal Opportunity we operate. These policies describe the conduct that is Providing Equal Opportunity not report it or address it, it is as if you condoned or and Respecting Diversity prohibited and establish procedures for raising concerns and Respecting Diversity engaged in the conduct yourself. All of our supervisors Preventing Harassment and reporting violations. They set expectations of our >Preventing Harassment and managers should be familiar with our policies on Maintaining the Privacy of managers and define the roles of the Human Resources, Personal Information Maintaining the Privacy of harassment and their obligations for handling complaints Personal Information Legal and Compliance Departments in reporting, Health and Safety and reporting violations of policy. Health and Safety investigations and follow-up. Finally, they provide that Conduct Relating To Our anyone engaging in conduct in violation of our anti- Business Partners, Clients And Conduct Relating To Our LEARN MORE ABOUT PREVENTING HARASSMENT Competitors Business Partners, Clients And harassment policies will be held personally responsible. Competitors Conduct Relating To CBRE’s Harassment may take many forms, from overt sexual Conduct Relating To CBRE’s Resources advances to offhanded remarks or jokes, to offensive Resources Conduct Relating To Our gestures, regardless of the intent. We recognize that each Communities Conduct Relating To Our country and culture has somewhat different views of the Communities type of conduct that is acceptable among colleagues Conclusion Conclusion in the workplace. However, these differences tend to be minor. Overemphasizing these differences can distract us from the fundamental truth—all of our colleagues deserve to be treated with dignity and respect and not be subjected to offensive or degrading behavior.
Regardless of where Company policy sets the bar in terms of prohibited inappropriate or harassing behavior, it is easy to stay in compliance with our harassment-related policies by asking yourself a few simple questions:
Who should I contact for Would you like a family member to be treated the help? You may contact Senior Who should I contact for same way? Management or one of the Conduct Relating To Each Other help? You may contact Senior following: Chief Compliance Would you be acting the same way or say the same thing Policy Guidance Management or one of the Harassment-Free Workplace Officer • CBRE Ethics HelpLine: following: Chief Compliance if a family member or our CEO were present? 800.799.6523 • Human Officer • CBRE Ethics HelpLine: Resources • Legal CBRE Standards of Business Conduct 12 800.799.6523 • Human Resources • Legal CBRE Standards of Business Conduct 14
From The Board Of Directors Respect is the first of our RISE values, and for good reason. national origin*, religion, gender or gender identity, sexual From The Board Of Directors Maintaining the Privacy of LEARN MORE ABOUT MAINTAINING THE PRIVACY OF PERSONAL INFORMATION When we are treated with respect, we are motivated to orientation, age, marital status, disability, veteran status). A Message From Our CEO A Message From Our CEO Personal Information succeed in our own careers and to help others succeed Discrimination on the basis of any classification protected Introduction in theirs. When our role on the team is respected, we are by law is not tolerated by CBRE. Introduction energized to work for the team’s success. Conduct Relating To Each Other In many countries, we embrace our legal obligation to Conduct Relating To Each Other >Providing Equal Opportunity As CBRE’s platform has expanded and strengthened take affirmative action to promote hiring and advancement Providing Equal Opportunity and Respecting Diversity globally, we increasingly have the opportunity to interact in employment among people within certain protected and Respecting Diversity Preventing Harassment with clients and colleagues across business lines and classifications. We believe doing so is the right thing to do Preventing Harassment Maintaining the Privacy of geographies, regardless of where we work within and good for our business. >Maintaining the Privacy of Personal Information Personal Information the organization. The more we collaborate with our Health and Safety Health and Safety colleagues, the more powerful the CBRE platform becomes LEARN MORE ABOUT PROVIDING EQUAL Conduct Relating To Our OPPORTUNITY AND RESPECTING DIVERSITY and the more enjoyable our work becomes. Whether our Conduct Relating To Our Business Partners, Clients And Business Partners, Clients And Competitors colleague is in the cubicle next to us or half a world away, Competitors the standards for how we interact with each other are Conduct Relating To CBRE’s CBRE respects the privacy of our personal information fundamental to the CBRE culture and the RISE value of Conduct Relating To CBRE’s Resources Resources Respect. Some of these are outlined below: and complies with the laws that dictate how employers must treat such information. We will not disclose Conduct Relating To Our Conduct Relating To Our Communities Providing Equal Opportunity and Respecting Communities confidential information about our employees unless Diversity we are required to do so by applicable law. Each Conclusion As an employer, CBRE attracts the most talented people Conclusion employee must take special care in the handling from all walks of life. We provide an environment where of other employees’ personal information. CBRE is Policy Guidance everyone who chooses to join our team can compete committed to maintaining the privacy and security • Access to Employee Records and succeed according to their skills and abilities. We of all personal information. We will strive to design • Confidentiality/Non-disclosure encourage everyone who works for CBRE to make our systems and policies to maintain only such • Electronic Communication meaningful contributions and be recognized and rewarded information as we need for effective administration accordingly. Regardless of their backgrounds or position of our Company and require all employees to follow within the firm, our colleagues should always expect to be our security procedures to ensure that only authorized treated with dignity and respect. people have access to personal information.
CBRE is committed to providing equal opportunity in all employment practices including hiring, work assignments, Who should I contact for Who should I contact for help? You may contact Senior promotions and compensation. We make employment Policy Guidance help? You may contact Senior Management or one of the decisions based on merit and without regard to any • Equal Employment Opportunity • Non-Retaliation Management or one of the following: Chief Compliance factor protected by applicable law (e.g., race, color, following: Chief Compliance Officer • CBRE Ethics HelpLine: Officer • CBRE Ethics HelpLine: 800.799.6523 • Human 800.799.6523 • Human Resources • Legal *In some countries where there is a legal obligation that affects hiring by CBRE Standards of Business Conduct 13 Resources • Legal CBRE Standards of Business Conduct 15 national origin, we will comply with the local law.
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From The Board Of Directors Health and Safety customary to have alcoholic beverages at company From The Board Of Directors Integrity and Fair Dealing with the rules governing our business and to operate functions. However, regardless of where these events We exist and succeed due to the trust we have with the utmost reliability and transparency, especially A Message From Our CEO CBRE is committed to providing a safe workplace A Message From Our CEO and to enhancing the health and well-being of our are held, this SOBC and our other rules and policies earned for integrity and fair dealing. The trust of our when the interests of clients or employees are at stake. Introduction employees. Our success in meeting this commitment regarding workplace conduct are in effect and will be Introduction clients, stockholders and employees is CBRE’s most In addition, we recognize that our competitors have entered into contracts and we will strive to respect Conduct Relating To Each Other depends on each of us doing his or her part. CBRE enforced. Employees should be mindful that they are Conduct Relating To Each Other valuable asset. Our RISE value of Integrity requires provides the resources for a robust health and safety representing CBRE and our reputation at all times. that we always “take the high road” and deal fairly them and not unduly interfere in a way perceived to be Providing Equal Opportunity Conduct Relating To Our program, complete with a formal policy, training and a and honestly with our clients, employees, business unfair competition. and Respecting Diversity Business Partners, Clients And cadre of specialists supporting client accounts and our LEARN MORE ABOUT HEALTH AND SAFETY partners and even our competitors. As such, no one Preventing Harassment Competitors When we recruit employees from competitors, we own locations. However, we all play a role in minimizing representing CBRE will take unfair advantage of Maintaining the Privacy of >Integrity and Fair Dealing expect them to comply with and honor any agreements Personal Information the chances of on-the-job injuries by complying with the anyone through manipulation, fraudulent inducements Conflicts of Interest between and other legal obligations that they have with their >Health and Safety law, CBRE policy and common sense. For example, we or concealment, abuse of confidential or privileged Employees and CBRE current or former employer(s) (e.g., confidentiality, require anyone driving for CBRE business to comply with information, interference with a known contractual Conduct Relating To Our Competing with CBRE or non-solicit or non-competition agreements). CBRE Business Partners, Clients And all local driving laws (including those that require drivers its Clients—Corporate relationship or any other unfair-dealing. No monetary Opportunities does not want to receive any confidential or proprietary Competitors and passengers to wear seatbelts) and to refrain from benefit is worth conducting business in this manner. Participating in Public and information or trade secrets of our recruits’ current distracted driving (e.g., texting while driving). Any profit or gain based on disregarding our values is Conduct Relating To CBRE’s Political Affairs or former employers. Any employment offer would Resources temporary and causes more harm in the long run. If something occurs in our facility that might be Participating in Social Media be contingent upon the recruit providing us proof Conduct Relating To Our harmful to our employees or the community, we openly Solicitation of Colleagues that they are free to work in our organization without Communities communicate these situations and develop a plan Fair Competition compromising the integrity of their agreements and Dealing with Government that they have returned any property or information Conclusion to correct them effectively and quickly. We expect all Entities; Anticorruption belonging to their former employers. employees to report any unsafe conditions, whether at Export Controls our own workplace or one that we manage, and we will Competitive Intelligence Fiduciary Duties never retaliate against an employee for bringing any Our Clients’ Information The nature of the real estate services business often incident or condition to our attention. Therefore, if you Copyrights of Others results in CBRE owing “fiduciary duties” to third become aware of any hazardous situations; injuries, Conduct Relating To CBRE’s parties, most often our clients. A fiduciary duty is regardless of how minor or severe; or threat to the Resources the highest standard of duty under the law. Owing a safety or health of a colleague, client, vendor or other fiduciary obligation to someone requires us to place business partner, report it immediately to your supervisor Conduct Relating To Our Policy Guidance Communities that person’s interests above our own, to act with or the appropriate personnel within your location. • Drug-Free Workplace due care, to disclose conflicts of interest and to make • Employee Assistance Program We respect the contracts and commitments we have Conclusion our decisions in that person’s interests. Breaching a Because health and safety is a priority, while at work • Safe Workplace Policy made and strive to go beyond minimum compliance Who should I contact for Who should I contact for • Report of Injuries/Accidents we must remain free of the influence of alcohol, illegal • Smoke-Free Workplace help? You may contact Senior help? You may contact Senior drugs or any other substance that may impair our ability • Violence in the Workplace Management or one of the Management or one of the to work safely and effectively. We recognize that it is following: Chief Compliance following: Chief Compliance Officer • CBRE Ethics HelpLine: Officer • CBRE Ethics HelpLine: 800.799.6523 • Human 800.799.6523 • Human Resources • Legal CBRE Standards of Business Conduct 18 Resources • Legal CBRE Standards of Business Conduct 16
From The Board Of Directors From The Board Of Directors fiduciary obligation to a client can have serious legal Please seek guidance from a member of the Legal consequences to you, our clients and CBRE. When or Compliance Departments if you are unsure as to A Message From Our CEO A Message From Our CEO representing clients, you are expected to comply with whether fiduciary duties exist in any situation or the Introduction Introduction all laws that govern our business operations, which appropriate course of conduct when interacting with Conduct Relating To Each Other Conduct Relating To Each Other typically require written disclosure and client consent the firm’s clients. of conflicts. Conduct Relating To Our Conduct Relating To Our Business Partners, Clients And Business Partners, Clients And LEARN MORE ABOUT INTEGRITY AND FAIR DEALING DUTIES Competitors Competitors Integrity and Fair Dealing >Integrity and Fair Dealing Conflicts of Interest between Policy Guidance Employees and CBRE Conflicts of Interest between • Internal Communications Employees and CBRE • Standards of Conduct Competing with CBRE or its Clients—Corporate Competing with CBRE or • Confidentiality/Non-disclosure Opportunities its Clients—Corporate • Managing Conflicts of Interests - Information Barriers Opportunities • Conflicts of Interest Participating in Public and Political Affairs Participating in Public and • Conflicts Identification and Management Policy for Political Affairs Government Contracts Participating in Social Media • Open Bidding Solicitation of Colleagues Participating in Social Media Fair Competition Solicitation of Colleagues Dealing with Government Fair Competition Entities; Anticorruption Dealing with Government Export Controls Entities; Anticorruption Competitive Intelligence Export Controls Our Clients’ Information Competitive Intelligence Copyrights of Others Our Clients’ Information Conduct Relating To CBRE’s Copyrights of Others Resources Conduct Relating To CBRE’s Conduct Relating To Our Resources Communities Conduct Relating To Our Conclusion Conduct Relating To Our Business Communities Who should I contact for Conclusion help? You may contact Senior Who should I contact for Management or one of the Partners, Clients And Competitors help? You may contact Senior following: Chief Compliance Management or one of the Officer • CBRE Ethics HelpLine: following: Chief Compliance 800.799.6523 • Human Officer • CBRE Ethics HelpLine: Resources • Legal CBRE Standards of Business Conduct 17 800.799.6523 • Human Resources • Legal CBRE Standards of Business Conduct 19
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From The Board Of Directors Conflicts of Interest between From The Board Of Directors a position of direct decision-making authority (e.g., Exchanging Gifts and Entertainment A conflict of interest arises when you or a close friend compensation) over another. If these relationships Exchanging business gifts and entertainment is a A Message From Our CEO Employees and CBRE A Message From Our CEO In any organization with tens of thousands of or family member has a financial stake in a company already exist, they must be disclosed so that we can customary practice throughout most of the world and that is a CBRE vendor, business partner or competitor. Introduction Introduction promotes good working relationships and goodwill employees, conflicts between personal and company In these situations, you must not use your position to take steps to protect the business and our reputation. interests are inevitable. So, while we cannot always influence the selection, bidding or negotiating process among vendors, clients and business partners. For Conduct Relating To Each Other Conduct Relating To Each Other LEARN MORE ABOUT CONFLICTS OF avoid conflicts, we can minimize their harmful impact in any way, particularly if the goods or services are INTEREST BETWEEN EMPLOYEES AND CBRE example, we recognize that it is customary and Conduct Relating To Our through the way we identify, disclose and manage them. being procured on behalf of a client account. You Conduct Relating To Our routine (indeed, often expected) for real estate sales Business Partners, Clients And Business Partners, Clients And should disclose the conflict to your manager and professionals to sponsor events and to entertain Competitors remove yourself from the selection process. Competitors We know that our employees have a broad range of clients or provide gifts in certain circumstances. CBRE Integrity and Fair Dealing personal and community interests and involvement. Integrity and Fair Dealing recognizes that gift-giving is synonymous with the > Conflicts of Interest between We strive to strike the right balance between > Conflicts of Interest between • You or a member of your immediate family owns holiday season and even an expected part of doing Employees and CBRE encouraging these pursuits and protecting our brand, Employees and CBRE an interest in a supplier, vendor, partner, contractor, business that time of year. In fact, many of our offices Competing with CBRE or reputation and bottom line. However, if the interests Competing with CBRE or its Clients—Corporate subcontractor or competitor of CBRE; or, its Clients—Corporate will be filled with mail-order fruit baskets, candy and Opportunities of an individual and the firm ever collide, we must Opportunities • Receiving any unusual gain, favors, gifts, other gifts sent from vendors, clients and others during always err on the side of CBRE and its clients. There is Participating in Public and kickbacks or other benefits as a result of one’s Participating in Public and the holiday season. Political Affairs Political Affairs no individual whose interests are more important than position in the Company. Participating in Social Media the collective organization. As you make decisions on Participating in Social Media We do not prohibit reasonable expenditures for Solicitation of Colleagues behalf of CBRE or participate in activities outside the The appearance of conflict can be just as damaging Solicitation of Colleagues travel, meals, entertainment, client events and gifts Fair Competition workplace, you must be aware of our policies dealing as an actual conflict, and can tarnish your reputation Fair Competition and similar or related expenses with a bona fide Dealing with Government with conflicts. Most of the time, using common sense within CBRE or our reputation for fair dealing. Dealing with Government and documented business purpose. However, gifts Entities; Anticorruption Entities; Anticorruption will result in the right answer; however, it is important Therefore, any action or personal interest that and entertainment, if excessive, could cause real or Export Controls Export Controls to know when to ask for help where you are unsure. causes or could be reasonably expected to cause a perceived conflicts of interest or at worst could be Competitive Intelligence Competitive Intelligence conflict of interest must be disclosed to us through alleged to be bribes or kickbacks. There is a line Our Clients’ Information Our Clients’ Information Conflicts of interest arise when a person representing established procedures and must have received prior between these customary gifts and the types of gifts or Copyrights of Others Copyrights of Others CBRE takes an action or has a personal or family approval, or else it is prohibited. When in doubt, you entertainment that are perceived to be excessive. Conduct Relating To CBRE’s interest that has the potential to affect his or her must disclose any factor that could even be perceived Conduct Relating To CBRE’s Resources objectivity, loyalty or work performance. Some as a conflict of interest with the Legal or Compliance Resources Policy Guidance Giving or receiving gifts is not appropriate if it creates common examples of conflicts between an employee Departments. Remember, if you are unsure, ask • Employment of Relatives an obligation, puts the giver or receiver in a situation Conduct Relating To Our Conduct Relating To Our • Outside Employment Communities and the firm include: before acting. In this area, making the wrong Communities • Conflicts of Interest where either appears to be biased or is done with the decision can have devastating consequences for you • Personal Ownership of Real Estate intent to influence a business decision. For example, Conclusion • Outside employment; Conclusion and the Company. gifts that are excessive or accepted under certain Who should I contact for • Outside work for or serving on the board of directors Who should I contact for questionable circumstances (e.g., from opposing help? You may contact Senior of a client, supplier, vendor or competitor of CBRE; Employment and Other Activities Outside the Company help? You may contact Senior Management or one of the • Political or community activities that could reflect We encourage our employees to play active roles in Management or one of the following: Chief Compliance negatively on the reputation of CBRE; their communities and in religious, environmental, following: Chief Compliance Officer • CBRE Ethics HelpLine: charitable or other outside organizations. Many of our Officer • CBRE Ethics HelpLine: 800.799.6523 • Human 800.799.6523 • Human Resources • Legal CBRE Standards of Business Conduct 20 Resources • Legal CBRE Standards of Business Conduct 22
From The Board Of Directors employees serve in leadership roles or on boards of It is a conflict of interest to supervise someone From The Board Of Directors parties in a deal or from a party with whom you are non-profit or charitable or even political organizations. with whom you have a romantic or close family negotiating a contract) could create a conflict of A Message From Our CEO A Message From Our CEO Sometimes, however, outside activities may create a relationship. Even if you are acting impartially, other interest or the perception of one. At worst, an excessive Introduction conflict of interest or could cause embarrassment to employees could perceive favoritism. As a result, Introduction gift could be considered a form of commercial bribery, Conduct Relating To Each Other CBRE. Therefore, CBRE reserves the right to prohibit the rest of the team’s productivity is disrupted and Conduct Relating To Each Other and therefore gifts cannot be given to anyone to help service on outside organizations. Taking employment morale is degraded. We recognize that we have CBRE acquire or retain business or to encourage that Conduct Relating To Our or a consulting engagement outside CBRE is permitted employed family members and close personal friends Conduct Relating To Our person to do something corrupt, deceitful or otherwise Business Partners, Clients And Business Partners, Clients And with the permission of your manager and only if: of our employees. We also recognize the reality that opposed to the person’s responsibilities. Competitors Competitors relationships often form and blossom among co- • The assignment is not with, or in aid of, a competitor Integrity and Fair Dealing workers. And whether they pre-existed or were recently Integrity and Fair Dealing Therefore, each country operation, region and or a vendor; > Conflicts of Interest between formed, we will take steps to manage the conflicts of > Conflicts of Interest between business has adopted policies, approved by the Employees and CBRE Employees and CBRE • The assignment does not conflict or interfere with interest and the perception of favoritism. Compliance Department, governing expenditures for Competing with CBRE or your CBRE job performance, responsibilities, hours Competing with CBRE or travel, meals, gifts and entertainment. These policies its Clients—Corporate or duties; its Clients—Corporate Gifts and Gratuities for Government Officials Opportunities Opportunities are designed to comply with all applicable laws and Our policies also acknowledge that stricter and more • The assignment does not require you to use CBRE Participating in Public and Participating in Public and regulations relating to those operations—while always specific rules and policies apply when we do business Political Affairs property, facilities or confidential information; Political Affairs fostering our RISE value of Integrity. with any government entity, agency or agent. The Participating in Social Media Participating in Social Media • In any publicity relating to the activity, you do laws of many countries prohibit the giving of anything Solicitation of Colleagues not associate the entity with CBRE without our Solicitation of Colleagues Please review our Gift and Entertainment Policy and of value to a government employee. And our global Fair Competition permission; or, Fair Competition our Anticorruption Policy for more guidance. Anticorruption Policy contains strict prohibitions on Dealing with Government • The assignment does not require the use of the same Dealing with Government Entities; Anticorruption Regarding giving gifts or entertaining clients on behalf providing anything that could be perceived as a bribe license that is used for your CBRE employment. Entities; Anticorruption Export Controls Export Controls of CBRE, a few simple principles apply: to gain or maintain any business advantage. Because Competitive Intelligence Serving on the board of directors of another for-profit of the sensitive nature of these relationships and the Competitive Intelligence • We believe that we offer the best services in the business is permitted only with permission of CBRE, Our Clients’ Information Our Clients’ Information industry—any business that has to be won by complexity of the laws in this area, we should always and permission may be conditioned on steps that Copyrights of Others Copyrights of Others providing unusual or excessive gifts or hospitality is review the applicable policy and seek advice from the must be taken to mitigate any real or perceived conflict Conduct Relating To CBRE’s Conduct Relating To CBRE’s business we do not need. Legal or Compliance Departments before offering any of interest. Resources Resources • We must be aware of, and respect, our clients’ own gifts or hospitality to government employees. Even if policies in these areas. Ask your client in advance the laws or customs in a particular country are vague, Conduct Relating To Our Close Friendships, and Romantic or Family Relationships We also believe that our managers are in a position of Conduct Relating To Our as a U.S. based company, the U.S. Foreign Corrupt Communities To be the strongest possible organization, we must trust similar to a teacher, and that it is improper for a Communities about its policy on accepting gifts and entertainment. Practices Act applies, regardless fo where we do make our business decisions based on merit and in manager to become romantically or sexually involved • We also must be sure that all expenditures have Conclusion Conclusion business. the best interests of CBRE. Favoritism in hiring or other with someone they supervise or who is in a subordinate been appropriately authorized and are correctly Who should I contact for employment decisions that results from any factor other Who should I contact for recorded on our books. help? You may contact Senior position within their business unit or department. Regarding the receipt of gifts and entertainment, no help? You may contact Senior • Gifts of cash and cash equivalents (i.e., anything Management or one of the than performance saps our strength by demoralizing Similarly, we believe that a close friend, family CBRE employee is authorized to accept any gift that Management or one of the readily exchanged for cash such as gift cards, following: Chief Compliance those who are most deserving. member or romantic partner should not be placed in could be perceived to improperly influence CBRE’s following: Chief Compliance vouchers, etc.) are prohibited. Officer • CBRE Ethics HelpLine: Officer • CBRE Ethics HelpLine: 800.799.6523 • Human 800.799.6523 • Human Resources • Legal CBRE Standards of Business Conduct 21 Resources • Legal CBRE Standards of Business Conduct 23
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Participating in Public and Political Affairs LEARN MORE ABOUT PARTICIPATING IN PUBLIC AND POLITICAL AFFAIRS From The Board Of Directors business or purchasing decisions or any decisions follow instructions regarding how to deal with the From The Board Of Directors CBRE employees are encouraged to participate in on behalf of any client. If you are offered a gift that gift. If you are unsure about whether you can accept policy, educational and political matters that affect A Message From Our CEO A Message From Our CEO is inappropriate, politely decline. If refusing the gift a particular gift or invitation, ask your manager or our lives, communities and business. Many of our Introduction would embarrass or hurt the person offering it, you someone in Compliance or the Legal Departments Introduction employees hold elected office, are members of local boards or commissions, or get involved with political Conduct Relating To Each Other may accept it on behalf of CBRE and then immediately for guidance. If you are not able to ask, you should Conduct Relating To Each Other report it to a member of senior management and politely decline the offer. and/or educational campaigns. These activities often Conduct Relating To Our Conduct Relating To Our require public speaking, publishing opinion pieces, or Business Partners, Clients And LEARN MORE ABOUT EXCHANGING GIFTS AND ENTERTAINMENT Business Partners, Clients And giving interviews to media. When engaging in these Competitors Competitors activities, no employee is permitted to use CBRE’s Integrity and Fair Dealing Integrity and Fair Dealing name or logo, or identify themselves as being affiliated > Conflicts of Interest between Policy Guidance Conflicts of Interest between with CBRE without obtaining prior written consent Employees and CBRE • Standards of Conduct Employees and CBRE • Inappropriate Entertainment from the Corporate Communications Department. We Competing with CBRE or Competing with CBRE or • Gifts and Entertainment its Clients—Corporate its Clients—Corporate ask that the leaders in our Company, including city Opportunities • Solicitation and Distribution Opportunities or regional market leaders, use common sense when • Anti-Corruption Policy Participating in Public and >Participating in Public and participating in any activity outside the office, including Political Affairs Political Affairs civic affairs. Even when not using CBRE’s name, your Participating in Social Media Participating in Social Media unique position and profile in the community means Solicitation of Colleagues Solicitation of Colleagues almost anything you say or do could be attributed to Fair Competition Fair Competition the Company. Dealing with Government Dealing with Government Entities; Anticorruption Entities; Anticorruption Corporate political contributions and lobbying of Export Controls Export Controls governments or their officials are strictly regulated in Competitive Intelligence Competitive Intelligence most countries. We have decided that CBRE will not Our Clients’ Information Our Clients’ Information make any political contributions and employees are Copyrights of Others Copyrights of Others not entitled to make them on CBRE’s behalf. CBRE will Conduct Relating To CBRE’s Conduct Relating To CBRE’s become involved in public affairs only through very Resources Resources Policy Guidance controlled procedures and with the approval of the • Political Contributions Conduct Relating To Our Conduct Relating To Our Legal Department. • Solicitation and Distribution Communities Communities • Use of CBRE Name or Identity
Conclusion Conclusion Who should I contact for Who should I contact for help? You may contact Senior help? You may contact Senior Management or one of the Management or one of the following: Chief Compliance following: Chief Compliance Officer • CBRE Ethics HelpLine: Officer • CBRE Ethics HelpLine: 800.799.6523 • Human 800.799.6523 • Human Resources • Legal CBRE Standards of Business Conduct 24 Resources • Legal CBRE Standards of Business Conduct 26
Competing with CBRE or its Clients— LEARN MORE ABOUT COMPETING Participating in Public and Political Affairs LEARN MORE ABOUT PARTICIPATING WITH CBRE OR ITS CLIENTS IN PUBLIC AND POLITICAL AFFAIRS From The Board Of Directors Corporate Opportunities From The Board Of Directors CBRE employees are encouraged to participate in Competing with CBRE or its clients, either personally or policy, educational and political matters that affect A Message From Our CEO A Message From Our CEO by aiding a competitor, is strictly prohibited. Using your our lives, communities and business. Many of our Introduction contacts or position within the Company to advance Introduction employees hold elected office, are members of local your own business or financial interests in competition boards or commissions, or get involved with political Conduct Relating To Each Other Conduct Relating To Each Other with CBRE or its clients is improper. and/or educational campaigns. These activities often Conduct Relating To Our Conduct Relating To Our require public speaking, publishing opinion pieces, or Business Partners, Clients And Through your position at CBRE you might become Business Partners, Clients And giving interviews to media. When engaging in these Competitors Competitors aware of an opportunity to provide a service or make activities, no employee is permitted to use CBRE’s Integrity and Fair Dealing an investment that could have been provided or Integrity and Fair Dealing name or logo, or identify themselves as being affiliated Conflicts of Interest between made by CBRE itself. As employees, we owe CBRE Conflicts of Interest between with CBRE without obtaining prior written consent Employees and CBRE an undivided duty to advance its business interests Employees and CBRE from the Corporate Communications Department. We >Competing with CBRE or when the opportunity to do so arises. Accordingly, Competing with CBRE or ask that the leaders in our Company, including city its Clients—Corporate if you become aware of an opportunity that could its Clients—Corporate Opportunities Opportunities or regional market leaders, use common sense when be provided to CBRE, you must disclose it to your Participating in Public and >Participating in Public and participating in any activity outside the office, including Political Affairs manager or a member of senior management so that Political Affairs civic affairs. Even when not using CBRE’s name, your Participating in Social Media CBRE can evaluate it. Only if CBRE has declined the Participating in Social Media unique position and profile in the community means Solicitation of Colleagues opportunity (in writing) are you permitted to act on it Solicitation of Colleagues almost anything you say or do could be attributed to Fair Competition for yourself personally (or for a family member). Fair Competition the Company. Dealing with Government Dealing with Government Entities; Anticorruption In addition, the use of CBRE or client resources or Policy Guidance Entities; Anticorruption Corporate political contributions and lobbying of Export Controls vendors, suppliers or subcontractors to perform • Confidentiality/Non-disclosure Export Controls governments or their officials are strictly regulated in • Conflicts of Interest Competitive Intelligence work at your personal residence, a family member’s Competitive Intelligence most countries. We have decided that CBRE will not Our Clients’ Information residence or for you or a family member’s outside Our Clients’ Information make any political contributions and employees are Copyrights of Others business may occur only with prior approval of the Copyrights of Others not entitled to make them on CBRE’s behalf. CBRE will Conduct Relating To CBRE’s senior management in your business unit. Conduct Relating To CBRE’s become involved in public affairs only through very Resources Resources Policy Guidance Because your personal ownership of certain types controlled procedures and with the approval of the • Political Contributions Conduct Relating To Our of real estate poses both legal and reputational Conduct Relating To Our Legal Department. • Solicitation and Distribution • Use of CBRE Name or Identity Communities ramifications to CBRE, we have established clear Communities Conclusion policies regarding employee ownership of real property Conclusion Who should I contact for and participation in aspects of the real estate markets. Who should I contact for help? You may contact Senior help? You may contact Senior Management or one of the Management or one of the following: Chief Compliance following: Chief Compliance Officer • CBRE Ethics HelpLine: Officer • CBRE Ethics HelpLine: 800.799.6523 • Human 800.799.6523 • Human Resources • Legal CBRE Standards of Business Conduct 25 Resources • Legal CBRE Standards of Business Conduct 26
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Solicitation of Colleagues charitable purposes provided that this activity does Dealing with Government a century of hard work by thousands of employees, From The Board Of Directors In many cultures, it is uncomfortable and even not interfere with business operations or put anyone From The Board Of Directors Entities; Anticorruption it can be harmed by just one employee offering a offensive to be subjected to any pressure, however at CBRE under pressure to purchase a product or Our business dealings on behalf of our clients put bribe or kickback in any form. Aside from damaging A Message From Our CEO A Message From Our CEO subtle, to participate in our colleagues’ personal participate in a program. In addition, requiring any us in direct contact with local, state and federal our reputation, corruption allegations can lead to Introduction endeavors. Office management may permit an employee to participate in a religious prayer or ritual, Introduction government officials. And while we strive to maintain costly and disruptive government investigations, large occasional sale of products or solicitation for whether in or outside the office, is prohibited. good relationships, there are very specific rules that fines and criminal penalties against CBRE and the Conduct Relating To Each Other Conduct Relating To Each Other govern our interactions with government officials. For individuals involved. Conduct Relating To Our LEARN MORE ABOUT SOLICITATION OF COLLEAGUES Conduct Relating To Our example, although it might be acceptable practice in We have adopted a Global Anticorruption Policy Business Partners, Clients And Business Partners, Clients And the private sector, the exchanging of gifts—including Competitors prohibiting the offering or paying of bribes by any Competitors meals, entertainment, transportation or lodging—with Policy Guidance employee or agent of the Company. This prohibition Integrity and Fair Dealing Integrity and Fair Dealing government officials is often strictly prohibited. Aside • Solicitation and Distribution extends to payments to both government entities and Conflicts of Interest between • Electronic Communication Conflicts of Interest between from violating the law, it is possible that a misstep in Employees and CBRE commercial ones. No manager can override this Employees and CBRE this area would put our clients’ projects and businesses Competing with CBRE or prohibition or any other provision of the Policy. The Competing with CBRE or (and therefore our own) at risk. its Clients—Corporate its Clients—Corporate prohibition extends to doing these things indirectly Opportunities Opportunities through third parties while knowing that the third Participating in Public and Participating in Public and Political Affairs Political Affairs party will make the prohibited payments. Additional Participating in Social Media Participating in Social Media guidance on the types of payments that are prohibited >Solicitation of Colleagues Solicitation of Colleagues or permitted is included in the Policy and available Fair Competition Fair Competition from your Legal Department. To minimize the exposure Dealing with Government >Dealing with Government to potential liability from unauthorized actions of Entities; Anticorruption Entities; Anticorruption representatives working on our behalf, we have Export Controls Export Controls adopted carefully designed procedures for selecting, Competitive Intelligence Competitive Intelligence vetting and managing our business partners who Our Clients’ Information Our Clients’ Information interact with government officials on our behalf and Copyrights of Others Copyrights of Others requirements for standard provisions in our contracts Conduct Relating To CBRE’s Conduct Relating To CBRE’s with them. The Policy also sets forth the requirement Resources Resources that we maintain accurate books and records so that no questionable transaction can possibly be obscured Conduct Relating To Our Conduct Relating To Our Regardless of the market in which we operate, clients Communities Communities choose CBRE not only for our outstanding service, but and parameters for the strong financial controls because of our reputation for fair and ethical business necessary to comply with our obligations under the Conclusion Conclusion dealings. While this reputation has been built over anticorruption laws. Each of our operations has Who should I contact for Who should I contact for help? You may contact Senior help? You may contact Senior Management or one of the Management or one of the following: Chief Compliance following: Chief Compliance Officer • CBRE Ethics HelpLine: Officer • CBRE Ethics HelpLine: 800.799.6523 • Human 800.799.6523 • Human Resources • Legal CBRE Standards of Business Conduct 28 Resources • Legal CBRE Standards of Business Conduct 30
Fair Competition If you are unsure of the right decision to make, adopted policies regarding gifts, travel, entertainment form of corruption and to report violations. Violating From The Board Of Directors CBRE competes in markets and business lines all please seek the advice of the Legal or Compliance From The Board Of Directors and hiring that are consistent with our global these rules, whether or not intentional, could result in around the world. We compete solely on the merits of Departments. anticorruption compliance program. serious consequences for you and CBRE. You should A Message From Our CEO A Message From Our CEO our services, the prices we charge and the client loyalty always seek guidance from the Legal or Compliance LEARN MORE ABOUT FAIR COMPETITION Each individual at all levels of the Company has the Introduction we earn from a job well done. Our RISE values require Introduction Departments if you have any questions. personal responsibility to resist participation in any that we support free competition and compete fairly Conduct Relating To Each Other Conduct Relating To Each Other and ethically and in a manner consistent with the laws LEARN MORE ABOUT DEALING WITH GOVERNMENT ENTITIES; ANTICORRUPTION Conduct Relating To Our of each country in which we do business. The laws Conduct Relating To Our Business Partners, Clients And relating to competition (e.g., antitrust) are complex Business Partners, Clients And Competitors Competitors and violations carry severe penalties, including fines Policy Guidance Integrity and Fair Dealing and jail time for individual employees. Thus, all of us Integrity and Fair Dealing • Political Contributions • Anti-Corruption Policy Conflicts of Interest between must ensure that our conduct is consistent with our Conflicts of Interest between Employees and CBRE values and the laws. A few helpful tips for compliance Employees and CBRE Competing with CBRE or Competing with CBRE or its Clients—Corporate in this area follow: its Clients—Corporate Opportunities Opportunities • Avoid any discussions with competitors regarding Participating in Public and Participating in Public and Political Affairs pricing of services unless the discussions have an Political Affairs appropriate business purpose and then, keep the Participating in Social Media Participating in Social Media discussions to a minimum. Solicitation of Colleagues Solicitation of Colleagues >Fair Competition • Do not enter into any agreement with a competitor Fair Competition except as approved by the Legal or Compliance Dealing with Government >Dealing with Government Entities; Anticorruption Departments (e.g., co-brokerage or data sharing). Entities; Anticorruption Export Controls • Certain types of agreements with competitors are Export Controls Competitive Intelligence always illegal and must be avoided regardless of Competitive Intelligence Our Clients’ Information the circumstances (e.g., agreeing with competitors Our Clients’ Information Policy Guidance Copyrights of Others on prices we or they will charge, standing down or Copyrights of Others colluding on a competitive bid, or dividing territories • Personal Ownership of Real Estate Conduct Relating To CBRE’s • Conflicts of Interest Conduct Relating To CBRE’s or clients). If a conversation with a competitor Resources Resources enters an inappropriate area, end the conversation Conduct Relating To Our at once and report it to the Legal Department or Conduct Relating To Our Communities Compliance. Communities
Conclusion • Always be truthful about our competition’s services. Conclusion Who should I contact for • Avoid any action that could be alleged to be an Who should I contact for help? You may contact Senior illegal interference with a competitor’s contractual help? You may contact Senior Management or one of the relationship with a third party (e.g., its client). Management or one of the following: Chief Compliance following: Chief Compliance Officer • CBRE Ethics HelpLine: Officer • CBRE Ethics HelpLine: 800.799.6523 • Human 800.799.6523 • Human Resources • Legal CBRE Standards of Business Conduct 29 Resources • Legal CBRE Standards of Business Conduct 31
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Our Clients’ Information it. Any mistake in handling it could subject you and CBRE STANDARDS OF BUSINESS CONDUCT From The Board Of Directors We know a lot about our clients, and their trust in us CBRE to liability. For these reasons, it is a violation of is a priceless asset. Our RISE values of Integrity and policy, and in some cases the law, to disclose or use A Message From Our CEO Service require that we handle others’ confidential client information for anything other than the purpose Introduction information at least as carefully as we would our own. for which the information is entrusted with us. All of Any inappropriate use of confidential client information us must be sure to follow the same security measures Conduct Relating To Each Other weakens that trust and our relationship with our for client information that we do for our own sensitive Conduct Relating To Our clients. In addition, acceptance of client confidential CBRE information. Business Partners, Clients And information creates a legal responsibility to protect Competitors
Integrity and Fair Dealing LEARN MORE ABOUT OUR CLIENTS’ INFORMATION Conflicts of Interest between Employees and CBRE Competing with CBRE or Policy Guidance its Clients—Corporate • Information Asset Protection Opportunities • Confidentiality/Non-disclosure Participating in Public and Political Affairs Participating in Social Media Solicitation of Colleagues Fair Competition Dealing with Government Entities; Anticorruption Export Controls Competitive Intelligence >Our Clients’ Information Copyrights of Others Conduct Relating To CBRE’s Resources
Conduct Relating To Our Communities
Conclusion Who should I contact for help? You may contact Senior Management or one of the following: Chief Compliance Officer • CBRE Ethics HelpLine: 800.799.6523 • Human Resources • Legal CBRE Standards of Business Conduct 34
Competitive Intelligence • We will not use confidential information obtained Copyrights of Others on an intranet or extranet, may be a violation of From The Board Of Directors Competitive information can be valuable to us to from another company, especially if it is marked From The Board Of Directors We will not misuse the copyrighted material of any copyright laws and CBRE policy and could subject us understand and manage our markets and services so “proprietary” or “confidential” (or information we other entity. Many publications and data sources to monetary penalties and other sanctions. If you are A Message From Our CEO A Message From Our CEO we can better meet our clients’ needs. However, we have reason to think should have been marked that carry restrictions on their use or are licensed to an in doubt regarding whether any material is copyrighted way), unless we have specific permission. If a third will gather and use information only in accordance Introduction individual within CBRE rather than the full Company. by someone else and whether it can be exploited for Introduction party attempts to share proprietary information with with the law and our high ethical standards and we Forwarding to CBRE employees or clients materials your or CBRE’s benefit, seek advice from the Legal Conduct Relating To Each Other you without a signed non-disclosure agreement in Conduct Relating To Each Other will respect the confidentiality of our competitors’ and place, do not accept it—stop the conversation. provided by other entities, or posting these materials Department. Conduct Relating To Our suppliers’ information. Any information we suspect has Conduct Relating To Our If you have any questions or believe that material LEARN MORE ABOUT OUR COPYRIGHTS OF OTHERS Business Partners, Clients And been obtained improperly must not be used. Business Partners, Clients And Competitors you possess may violate these standards, you should Competitors contact the Legal or Compliance Departments Integrity and Fair Dealing Integrity and Fair Dealing Policy Guidance immediately. Conflicts of Interest between Conflicts of Interest between Electronic Communications & Acceptable use of Employees and CBRE Employees and CBRE LEARN MORE ABOUT Technology: Social Media Competing with CBRE or COMPETITIVE INTELLIGENCE Competing with CBRE or its Clients—Corporate its Clients—Corporate Opportunities Opportunities Participating in Public and Participating in Public and Political Affairs Political Affairs Participating in Social Media Participating in Social Media Solicitation of Colleagues Solicitation of Colleagues Fair Competition Fair Competition Dealing with Government Dealing with Government Entities; Anticorruption Entities; Anticorruption The law prohibits us from obtaining information Export Controls Export Controls through theft, blackmail, wiretapping, electronic Competitive Intelligence >Competitive Intelligence eavesdropping, hacking, pretexting, bribery, improper Our Clients’ Information Our Clients’ Information inducement, receiving stolen property, threats and >Copyrights of Others Copyrights of Others other improper methods. It is also important that we Conduct Relating To CBRE’s acquire competitive information ethically. Here are Conduct Relating To CBRE’s Resources Resources some guidelines: Conduct Relating To Our Conduct Relating To Our • We will not misrepresent who we are or for whom Communities Communities we work. Conclusion Conclusion • We will not use a competitor’s employees as Who should I contact for improper sources of non-public information. Who should I contact for help? You may contact Senior help? You may contact Senior • CBRE employees or recruits should not divulge to us Policy Guidance Management or one of the Management or one of the proprietary information about their other employers, Restrictions on Marketing by Fax following: Chief Compliance following: Chief Compliance and we should not ask them to. Officer • CBRE Ethics HelpLine: Officer • CBRE Ethics HelpLine: 800.799.6523 • Human 800.799.6523 • Human CBRE Standards of Business Conduct 35 Resources • Legal CBRE Standards of Business Conduct 33 Resources • Legal
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Our Reputation and Brand valuable creations belong to CBRE. Similar to desks, From The Board Of Directors From The Board Of Directors We are the industry leader, and CBRE is the most printers and office supplies, employees may not take recognizable and powerful brand in the real estate intellectual property at the end of their employment. A Message From Our CEO A Message From Our CEO services industry. We gained this position through a LEARN MORE ABOUT OUR REPUTATION AND BRAND Introduction Introduction relentless focus on serving the clients’ interests and maintaining our RISE values. We built our reputation Conduct Relating To Each Other Conduct Relating To Each Other for Respect, Integrity, Service and Excellence over Conduct Relating To Our Conduct Relating To Our decades, but recognize that a reputation can be Business Partners, Clients And Business Partners, Clients And Competitors weakened or destroyed by just one action of one Competitors employee. We don’t produce products, and therefore Conduct Relating To CBRE’s Resources Conduct Relating To CBRE’s all of our interactions together represent our work Resources and our brand. We must strive in all of our work Protection and Proper Use of Company Property Protection and Proper Use of and interactions on behalf of CBRE to protect the Company Property Our Reputation and Brand reputation of the brand. >Our Reputation and Brand Our Confidential and Proprietary Information Our Confidential and Over the years, we have seen how the actions or Electronic Communication Proprietary Information activities of some individuals outside the context of Systems Electronic Communication work have been associated with CBRE, whether rightly Dealing with the Media and Systems or wrongly. Thus, our leaders within the company must other Requests for Information Dealing with the Media and ensure that nothing they do at work or in their personal Accuracy of Books and Records other Requests for Information lives will adversely impact the brand. Retention of Business Records Accuracy of Books and Records Cooperating with Investigations Retention of Business Records The brand CBRE and the logo that represents it Insider Trading Cooperating with Investigations are trademarks that are registered and recognized Conduct Relating To Our Insider Trading around the world. We have set out specific guidelines Communities Conduct Relating To Our for the use of the marks globally, including specific Communities Conclusion color palettes, fonts and other attributes that make Conclusion the marks immediately recognizable throughout the world. We must adhere to these standards and Policy Guidance take all appropriate steps to protect the brand • Use of CBRE Name or Identity and marks. In addition, all publications, materials, • Use of Company Property Who should I contact for databases and other programs developed by or for • Electronic Communication help? You may contact Senior • Conflicts of Interest Who should I contact for CBRE are intellectual property belonging to CBRE. Management or one of the Conduct Relating To CBRE’s Resources help? You may contact Senior following: Chief Compliance Employees are required to acknowledge that these Management or one of the Officer • CBRE Ethics HelpLine: following: Chief Compliance 800.799.6523 • Human Officer • CBRE Ethics HelpLine: Resources • Legal CBRE Standards of Business Conduct 36 800.799.6523 • Human Resources • Legal CBRE Standards of Business Conduct 38
Protection and Proper Use of LEARN MORE ABOUT PROTECTION AND PROPER Our Confidential and Proprietary Information USE OF COMPANY PROPERTY From The Board Of Directors Company Property From The Board Of Directors Our confidential and proprietary information gives A few words of wisdom about securing our us a competitive edge in the marketplace. It would confidential information: A Message From Our CEO A Message From Our CEO harm the Company if it were disclosed inappropriately. • Remember to mark all proprietary information as “Con- fidential.” All electronic mail documents must be treated Introduction Introduction In addition, as a public company we must be similarly to sensitive paper documents. extremely careful that we control the disclosure of Conduct Relating To Each Other Conduct Relating To Each Other • Be aware of who might be listening when you are material information about our business. Company speaking about confidential matters—never talk about Conduct Relating To Our Conduct Relating To Our policy requires all of us to keep CBRE’s confidential confidential matters in public areas such as elevators, taxis or restaurants. If you must, change names or speak Business Partners, Clients And Business Partners, Clients And information secure. This applies to information about Competitors Competitors in code. our finances, strategies, operations, clients and • Do not share confidential information even within CBRE Conduct Relating To CBRE’s Conduct Relating To CBRE’s compensation. It also applies equally to information unless you are sure that the recipient has the need to Resources Resources belonging to our employees and clients. know that information. If you are about to make them CBRE’s facilities, equipment, materials, property, “inside” on information, then you need to tell them >Protection and Proper Use of Protection and Proper Use of before disclosing the information. Company Property technology, information and brand have been Company Property • If you are required to disclose confidential information Our Reputation and Brand Our Reputation and Brand acquired through the hard work of tens of thousands to a third party in the course of your job, you should do Our Confidential and of people over a long period of time. Company > Our Confidential and so only under a written non-disclosure agreement in a Proprietary Information Proprietary Information assets also include our intellectual property such as form approved by the Legal Department. Electronic Communication Electronic Communication • Do not leave confidential information lying visibly on Systems trademarks, business and marketing plans, salary Systems your desk or other places where it can be seen by Dealing with the Media and information and any unpublished financial data and Dealing with the Media and unauthorized persons. Follow required procedures for other Requests for Information reports. We have a duty to safeguard these assets other Requests for Information safeguarding and disposing of confidential information, Accuracy of Books and Records against theft, loss, waste or damage and ensure we Accuracy of Books and Records rather than throwing it away in an ordinary garbage can. Retention of Business Records use them only in the most efficient and sustainable Retention of Business Records Cooperating with Investigations way. CBRE property should be used for legitimate Cooperating with Investigations • Never share your passwords with another person. Insider Trading business purposes only and we must take measures to Insider Trading • Avoid accessing questionable websites when using company computers. Conduct Relating To Our prevent their theft, damage or misuse. Conduct Relating To Our Communities Communities • Avoid transferring company data to a personal com- These days most confidential information is in the form puter. Conclusion Policy Guidance Conclusion of electronic data stored on our computers and other • Use of CBRE Name or Identity • Use of Company Property devices. Our IT Department is continually improving us must play our part and take common-sense steps our systems to protect sensitive information from to prevent the loss or unauthorized use of sensitive unauthorized access. Most protection occurs behind information. There are laws in many countries that the scenes and we don’t even notice it, but each of Who should I contact for Who should I contact for dictate what to do if any of our IT systems have been help? You may contact Senior help? You may contact Senior Management or one of the Management or one of the following: Chief Compliance following: Chief Compliance Officer • CBRE Ethics HelpLine: Officer • CBRE Ethics HelpLine: 800.799.6523 • Human 800.799.6523 • Human Resources • Legal CBRE Standards of Business Conduct 37 Resources • Legal CBRE Standards of Business Conduct 39
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breached, and these laws may be triggered if your Each employee is required to sign an acknowledge- Dealing with the Media and other Requests LEARN MORE ABOUT DEALING WITH THE MEDIA From The Board Of Directors computer, laptop or mobile device is lost, stolen or ment of his or her responsibilities to keep our infor- From The Board Of Directors for Information accessed by an unauthorized user. Therefore, please mation confidential. The obligations under this policy CBRE communicates about its business and matters A Message From Our CEO A Message From Our CEO be knowledgeable about your responsibilities to keep continue even after the employee leaves CBRE. relating to commercial real estate with the public and Introduction CBRE’s information systems and devices secure, and Introduction its investors directly and indirectly through the media. what to do if they are compromised. We endeavor to cooperate with the media where Conduct Relating To Each Other Conduct Relating To Each Other appropriate, but it is important that CBRE speak to the LEARN MORE ABOUT OUR CONFIDENTIAL AND PROPRIETARY INFORMATION Conduct Relating To Our Conduct Relating To Our media and investors with one unified voice. Therefore, Business Partners, Clients And Business Partners, Clients And only designated individuals are authorized to speak Competitors Competitors Policy Guidance on behalf of CBRE. Dealing with the media, financial Conduct Relating To CBRE’s • Information Asset Protection Conduct Relating To CBRE’s analysts or attorneys requires a special understanding Resources • Electronic Communication Resources of their needs and our obligations as a public • Confidentiality/Non-disclosure Protection and Proper Use of Protection and Proper Use of company. For example, as a public company we are Company Property Company Property committed to full compliance with the U.S. Securities Our Reputation and Brand Our Reputation and Brand and Exchange Commission’s Regulation FD (Fair > Our Confidential and Our Confidential and Disclosure). Here are a few guidelines that will keep us Proprietary Information Proprietary Information safely in compliance: Electronic Communication Electronic Communication Systems Systems • Refer any media calls or requests for interviews Dealing with the Media and >Dealing with the Media to your Marketing or Corporate Communications other Requests for Information and other Requests for Department. Accuracy of Books and Records Information • Refer questions from the financial community Retention of Business Records Accuracy of Books and Records Retention of Business Records (bankers, stockbrokers, stockholders or analysts) to Policy Guidance Cooperating with Investigations • Media Relations Cooperating with Investigations the Investor Relations Department or directly to our Insider Trading Chief Financial Officer. • Use of CBRE Name or Identity Insider Trading • Public Relations Conduct Relating To Our • Refer any questions about lawsuits, subpoenas or Communities Conduct Relating To Our Communities legal claims to the Legal Department. Conclusion • Questions about current or former employees should Conclusion be referred to the Human Resources Department. • Before publishing articles or opinion pieces, making speeches, giving interviews or making public appearances that are connected to our business, Who should I contact for Who should I contact for you must get approval as specified in our relevant help? You may contact Senior help? You may contact Senior policies in your location. Management or one of the Management or one of the following: Chief Compliance following: Chief Compliance Officer • CBRE Ethics HelpLine: Officer • CBRE Ethics HelpLine: 800.799.6523 • Human 800.799.6523 • Human Resources • Legal CBRE Standards of Business Conduct 40 Resources • Legal CBRE Standards of Business Conduct 42
Electronic Communication Systems During the last several years, the use of email and Accuracy of Books and Records The result these internal controls and procedures are From The Board Of Directors Our electronic communication systems, such as other messaging technologies has fundamentally From The Board Of Directors Whether we realize it or not, almost all of us contribute intended to achieve is guaranteed only if we maintain internet access, email, voice mail and telephone transformed communications. However, the ease in some way to creating CBRE’s financial statements. an environment of open communication, honesty A Message From Our CEO A Message From Our CEO services, are essential tools that support our business. with which these technologies can be used increases Whether you have prepared a timesheet in France, a and integrity throughout our entire organization— Introduction We must use our systems consistent with our RISE the risk of poor communication or misuse. Thus, we Introduction revenue voucher in India, an expense report in Chile there are no short-cuts. If you have concerns (or are values of Respect Integrity, Service and Excellence. should compose our emails and other electronic or purchased goods or services in Chicago, your contacted by anyone who has concerns) about any Conduct Relating To Each Other Conduct Relating To Each Other These systems are to be used primarily for Company messages with the same care taken in composing input is contributing to the ultimate reporting to our aspect of our financial disclosures, or any accounting Conduct Relating To Our business. While you may use the Company’s systems any other written document. These messages can be Conduct Relating To Our regulators and investors. All documents, reports or or audit or internal control issue, you must report them Business Partners, Clients And for incidental or occasional personal use, you must permanent and can be easily copied and forwarded Business Partners, Clients And information prepared for CBRE or at the request of immediately to your manager, or to any of the avenues Competitors Competitors recognize that you are not permitted to do so in any worldwide without your knowledge or permission. At someone with authority are important to ensure our we have made available in this SOBC to report issues, Conduct Relating To CBRE’s manner that may disrupt your or anyone else’s job worst, messages that advance personal or political Conduct Relating To CBRE’s financial reports are accurate as required by law. including the CBRE Ethics HelpLine. Resources performance or is otherwise offensive or contrary to views, or contain derogatory, profane, explicit or Resources We are required to provide our stakeholders with LEARN MORE ABOUT ACCURACY OF BOOKS AND our RISE values or other Company policies in any offensive content could be attributed to CBRE and Protection and Proper Use of RECORDS AND COOPERATING WITH INVESTIGATIONS Protection and Proper Use of full, accurate, timely and transparent reporting of Company Property degrade our brand or cause liability. Company Property information about CBRE. To fulfill this obligation, Our Reputation and Brand Our Reputation and Brand LEARN MORE ABOUT ELECTRONIC COMMUNICATION Our Confidential and every business record we create or approve must be Our Confidential and SYSTEMS & DEALING WITH THE MEDIA Proprietary Information Proprietary Information accurate, complete and reliable. We have adopted >Electronic Communication Electronic Communication specific policies and procedures to ensure we make Systems Systems full, fair, accurate and timely disclosures in our Dealing with the Media and Dealing with the Media and periodic filings with regulators, such as the U.S. other Requests for Information other Requests for Information Securities and Exchange Commission and the New Accuracy of Books and Records >Accuracy of Books and Records York Stock Exchange, and comply with our obligations Retention of Business Records Retention of Business Records under the law. We are also required to comply with the Cooperating with Investigations Cooperating with Investigations local and country-level corporations laws that govern Insider Trading Insider Trading our subsidiaries. Any failure to comply with these Conduct Relating To Our policies could subject the Company and its officers Communities Conduct Relating To Our Communities to significant financial liabilities and serious legal Conclusion sanctions. Conclusion manner. Our policies that govern how our systems All of us who are called upon to provide, review or are to be used reinforce these guidelines and give certify information in connection with any internal CBRE the right to monitor your use of our systems control or procedure must provide the most accurate, Policy Guidance Who should I contact for and to block, intercept or review any content or Who should I contact for timely and complete information possible. The Electronic Communication help? You may contact Senior communications that occur on or are stored in our help? You may contact Senior making or approving of false or misleading records or Policy Guidance Management or one of the systems. Your personal privacy is not protected on our Management or one of the documentation, or the failure to properly disclose any • Communications and Fair Disclosure Policy • Timekeeping following: Chief Compliance systems, and you should not expect it to be. following: Chief Compliance asset or liability, undermines our ability to make good Officer • CBRE Ethics HelpLine: Officer • CBRE Ethics HelpLine: decisions and is strictly prohibited. 800.799.6523 • Human 800.799.6523 • Human Resources • Legal CBRE Standards of Business Conduct 41 Resources • Legal CBRE Standards of Business Conduct 43
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Retention of Business Records LEARN MORE ABOUT RETENTION Insider Trading Your Legal Department can offer guidance to keep OF BUSINESS RECORDS From The Board Of Directors Properly maintaining our business records is vital to From The Board Of Directors Many of us will have access to information of which you from violating this Standard, the Securities Trading our compliance with laws and regulations. However, the general public is unaware, about CBRE, our Policy or the law, but only before you act. If you are A Message From Our CEO A Message From Our CEO knowing what documents and information to keep— clients, business partners and competitors. Often, unsure about this subject matter, you must refrain from Introduction and for how long—can be confusing. In fact, in the Introduction that information is considered “material,” meaning it trading or otherwise acting until you consult with the event of a lawsuit or investigation, we are required to would influence an individual’s decision whether to Compliance or Legal Departments and are certain that Conduct Relating To Each Other Conduct Relating To Each Other suspend usual document retention rules and preserve buy, sell or hold the stock of that company. Examples you are in compliance with our policy and the law. Conduct Relating To Our Conduct Relating To Our of “material” information include corporate earnings, evidence. The consequences of a wrong decision— LEARN MORE ABOUT INSIDER TRADING Business Partners, Clients And whether to retain too long or discard too soon—can Business Partners, Clients And line of business performance, potential acquisitions, Competitors Competitors be extremely costly. Keeping excess documents adds significant contract wins or losses, and lawsuits. As an Conduct Relating To CBRE’s costs to review and search in discovery and increases Conduct Relating To CBRE’s employee, it makes no difference how you obtain the Resources litigation risk. Resources information. The insider trading laws in the U.S. and Protection and Proper Use of Protection and Proper Use of many other jurisdictions where we operate (e.g., the Company Property In order to comply with all laws and regulations Company Property Market Abuse Directive in the U.K.) make it illegal for Our Reputation and Brand regarding the preservation of records, we have Our Reputation and Brand any of us, and our spouses, children and everyone Our Confidential and adopted policies in each country concerning the Our Confidential and else who lives in your home, from using material Proprietary Information Proprietary Information types of documents we are required to maintain and non-public information to trade in securities or tip off Electronic Communication Electronic Communication establishing retention schedules for each type of anyone else so that they can do so (even if you are Systems Systems record (including electronic records) and specifying unaware that they did). Because tipping is illegal, you Dealing with the Media and Dealing with the Media and other Requests for Information circumstances, such as lawsuits or investigations, other Requests for Information should be very careful not to disclose any confidential Accuracy of Books and Records when it is necessary to maintain or segregate certain Accuracy of Books and Records information to anyone who does not need to know it, >Retention of Business Records records. Records should be retained or destroyed only Retention of Business Records including close family members or friends. Cooperating with Investigations in accordance with the applicable company policy. Cooperating with Investigations Violation of these laws can have very serious Insider Trading Policy Guidance >Insider Trading repercussions for you (including large fines and Business Records Retention and Destruction Conduct Relating To Our Conduct Relating To Our even jail time) and potentially cause CBRE and its Communities Communities stakeholders inestimable financial damage. The Conclusion Conclusion Company has also adopted a Securities Trading Policy that applies to trading in CBRE’s publicly listed Policy Guidance securities, which all CBRE personnel must review and Securities Compliance agree to be bound to.
Who should I contact for Who should I contact for help? You may contact Senior help? You may contact Senior Management or one of the Management or one of the following: Chief Compliance following: Chief Compliance Officer • CBRE Ethics HelpLine: Officer • CBRE Ethics HelpLine: 800.799.6523 • Human 800.799.6523 • Human Resources • Legal CBRE Standards of Business Conduct 46 Resources • Legal CBRE Standards of Business Conduct 44
Cooperating with Investigations LEARN MORE ABOUT COOPERATING WITH INVESTIGATIONS From The Board Of Directors From time to time, our commitment to the RISE values From The Board Of Directors includes actively determining whether wrongdoing A Message From Our CEO A Message From Our CEO has occurred within our business. We will therefore Introduction commit the necessary resources when the need to Introduction investigate suspected misconduct arises. When this Conduct Relating To Each Other Conduct Relating To Each Other occurs, it is mandatory that all of our employees Conduct Relating To Our Conduct Relating To Our cooperate fully with the investigation so we can Business Partners, Clients And Business Partners, Clients And uncover the facts and take appropriate steps to Competitors Competitors rectify the situation promptly and thoroughly. We Conduct Relating To CBRE’s Conduct Relating To CBRE’s all have an obligation to cooperate with internal Resources Resources investigations, whether conducted by employees, Conduct Relating To Our Protection and Proper Use of outside consultants or counsel. If you are asked to Communities Company Property participate in any investigation, you must do so fully Our Reputation and Brand and candidly. If you receive a request or notice of a Corporate Responsibility Our Confidential and government investigation, you must communicate that Partnering with our Communities Proprietary Information to the Legal or Compliance Departments or senior Respecting the Environment Electronic Communication Conclusion Systems management immediately so that CBRE can cooperate Dealing with the Media and with the legitimate needs of the regulators and take other Requests for Information appropriate action. Accuracy of Books and Records Retention of Business Records Policy Guidance Investigations of Legal and Ethical Misconduct >Cooperating with Investigations Insider Trading Conduct Relating To Our Communities
Conclusion
Who should I contact for help? You may contact Senior Who should I contact for Management or one of the Conduct Relating To Our Communities help? You may contact Senior following: Chief Compliance Management or one of the Officer • CBRE Ethics HelpLine: following: Chief Compliance 800.799.6523 • Human Officer • CBRE Ethics HelpLine: Resources • Legal CBRE Standards of Business Conduct 47 800.799.6523 • Human Resources • Legal CBRE Standards of Business Conduct 45
78 10 | APPENDIX 10 | APPENDIX 79 STANDARDS OF BUSINESS CONDUCT 2015
From The Board Of Directors Corporate Responsibility From The Board Of Directors We each have an obligation to treat our colleagues encourage you to ask your supervisor or manager. If Our industry leadership carries with it an ethical and others with Respect, to represent CBRE with you do not feel comfortable doing this, please contact A Message From Our CEO A Message From Our CEO responsibility to our clients, employees, shareholders, unwavering Integrity, and to further the values of other CBRE resources that are available to you: Introduction communities and society at large. Corporate citizenship Introduction Service and Excellence that make our Company and living up to our core RISE values of Respect, • Your Supervisor or Manager Conduct Relating To Each Other Conduct Relating To Each Other great. These RISE values form the core of the Integrity, Service and Excellence are fundamental goals standards by which we should conduct our business. • Anyone in Senior Management Conduct Relating To Our of CBRE and its worldwide affiliates. To achieve these Respecting the Environment Conduct Relating To Our Each of these is a personal responsibility for all of us • Human Resources Department Business Partners, Clients And Business Partners, Clients And Competitors goals, CBRE has launched initiatives and programs in a Consistent with our corporate responsibility goals, CBRE representing CBRE, and we are each accountable for Competitors • Legal Department variety of areas to include environmental stewardship, is committed to becoming the industry leader in the area our individual actions. No illegal or unethical act can Conduct Relating To CBRE’s • Compliance Department ethics and compliance, governance, health and safety, of environmental sustainability. We are committed to Conduct Relating To CBRE’s be justified by claiming it was encouraged or ordered Resources and philanthropy. Our efforts are publicized in a yearly minimizing our environmental impact, and to assisting Resources by someone else. • CBRE HelpLine Conduct Relating To Our document called the Corporate Responsibility Report. It our clients in doing the same at their properties and Conduct Relating To Our Acknowledgement: Communities is located on our public website. organizations. We recognize our responsibility to be a While the SOBC cannot anticipate every situation that Communities Each year we will require each person subject to this steward of the environment and improve the quality of might arise in your business life at CBRE, applying >Corporate Responsibility Partnering with our Communities SOBC to certify that they have received and read the >Partnering with our life for our employees and for everyone who works at or Conclusion the principles supporting it can help us make the right A real estate services firm like CBRE needs to be SOBC, that they understand it, and that they agree to Communities visits our facilities. In addition, CBRE provides facilities decisions in most cases. When you need additional proactive in partnering with our communities. We should >Ask before Acting adhere to it during their employment with or service >Respecting the Environment and asset management services for clients owning or guidance or support, the SOBC informs you where you be aware of community needs and concerns as they >Remember these Rules to CBRE. Conclusion occupying billions of square feet of buildings globally, can seek information or help. involve our business and clients, and work constructively >Resources Are Available and supports thousands of clients in their procurement, with the right people and authorities to resolve issues >Acknowledgement CBRE appreciates your continuing support of the disposition and building of space for occupancy or Ask before Acting: and problems. CBRE’s corporate philanthropy efforts SOBC and the Ethics and Compliance Program and investment. We collaborate with them to optimize the • Is it legal? have always been driven by our dedicated professionals, your contribution to our success. performance and reduce the environmental impact of • Does it follow Company policy? who have enthusiastically moved our programs forward their properties. while widening and diversifying their scope. • Is it the right thing to do? CBRE is committed to good environmental practices, • How would it be perceived by our clients, the media CBRE has a long history of responding corporately to and we respond truthfully and responsibly to or our communities? For additional information, please contact: natural disasters. In our recent past, employees from questions and concerns of our stakeholders about our every region and line of business have answered the call Remember these Rules: environmental actions. We must obtain environmental Laurence Midler to assist victims across the globe, from earthquakes in • Know the legal and CBRE policies and standards Executive Vice President, General Counsel permits when required. Any waste materials left over that apply to your position. Haiti to floods in Pakistan. 213.613.3750 from our operations must be disposed of legally and • Never fail to follow these standards. [email protected] in a way that meets CBRE’s legal obligations under Who should I contact for If there is a cause in your community that fits within Tyson M. Avery environmental laws globally. • If you are unsure, ask someone who knows. help? You may contact Senior the corporate philanthropy strategy, speak to your Who should I contact for Chief Ethics and Compliance Officer, Global Compliance Management or one of the supervisor or manager. help? You may contact Senior Resources Are Available 213.613.3354 [email protected] following: Chief Compliance Management or one of the If you have questions or concerns about the “right Officer • CBRE Ethics HelpLine: following: Chief Compliance thing to do” or someone’s workplace conduct, we 800.799.6523 • Human Officer • CBRE Ethics HelpLine: Resources • Legal CBRE Standards of Business Conduct 48 800.799.6523 • Human Resources • Legal CBRE Standards of Business Conduct 50
From The Board Of Directors
A Message From Our CEO
Introduction
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
Conclusion
Ask before Acting Remember these Rules Resources Are Available Acknowledgement
Who should I contact for help? You may contact Senior Management or one of the Conclusion following: Chief Compliance Officer • CBRE Ethics HelpLine: 800.799.6523 • Human Resources • Legal CBRE Standards of Business Conduct 49
80 10 | APPENDIX 10 | APPENDIX 81 Aerial view of the campus
Elevate Your View