October 29, 2019

To our stakeholders:

I am pleased to reaffirm Cushman & Wakefield’s support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labor, Environment and Anti-Corruption.

In this annual Communication on Progress, we cover our environmental stewardship, commitment to diversity and inclusion, and governance directives for 2018. In addition to becoming a signatory of the UN Global Compact, we made significant progress on our corporate social responsibility objectives:

• We continued to align our firm’s strategy with five of the United Nations Sustainable Development Goals, which address global challenges and are considered the blueprint to achieve a better and more sustainable future for all.
• We were again named an ENERGY STAR® Partner of the Year by the U.S. Environmental Protection Agency.
• We improved our operational efficiency, reducing global greenhouse gas emissions 26% per $1 billion of revenue between 2017 and 2018.
• We continued to build a more diverse and inclusive workplace: 65% of managers hired in the U.S. were diverse, women represented 42% of new hires globally, and women comprised 40% of our external Board of Directors.
• And, we were recognized again as a best place to work by Forbes.

By all measures, 2018 was an outstanding year for our company with strong financial performance as we continued to build an integrated global services platform that delivers the best outcomes for clients. While we continue to make strong progress against our operational and financial goals, we remain equally committed to corporate citizenship. I’m proud that through this period of sustained growth we’ve remained true to our values as a company – operating with integrity and rigid ethical standards.

I invite you to continue reading our Communication on Progress to learn more about our progress and milestones.

Brett White

Executive Chairman & CEO

Cushman & Wakefield conducts business in a lawful and ethical manner and complies with all local, national and international human rights laws and regulations as they relate to our operations and those of our clients. We are committed to conducting business in accordance with the highest ethical standards, which are outlined in our Global Code of Business Conduct. Our standards apply to all Cushman & Wakefield directors, officers, partners, members, employees, temporary employees hired through agencies, brokerage professionals and independent contractors and vendors/suppliers.

Relative to business partners and suppliers, our Global Vendor/Supplier Integrity Policy clarifies our expectations in the areas of business integrity, labour practices, health, safety and environmental management. It affirms we conduct business responsibly, with integrity, honesty, and transparency, and adhere to the following principles:

• Provide safe, healthy and compliant working conditions
• Maintain awareness of and comply with all applicable laws and regulations of the countries where they operate, including but not limited to, all anti-corruption laws
• Compete fairly for the Company’s business, without paying bribes, kickbacks or giving anything of value to secure an improper advantage
• Encourage a diverse workforce and provide a workplace free from discrimination, harassment or any other form of abuse
• Treat employees fairly, including with respect to wages, working hours and benefits
• Prohibit all forms of forced or compulsory labor
• Prohibit use of child labor
• Carry out operations with care for the environment and comply with all applicable environmental laws and regulations
• Maintain accurate financial books and business records in accordance with all applicable legal and regulatory requirements and accepted accounting practices
• Support compliance with these Ethical Standards by establishing appropriate management processes and cooperating with reasonable assessment processes requested by the Company
• Conduct business in accordance with the Company’s policies regarding conflicts of interest, gifts and entertainment and charitable contributions (set forth in the Company’s Global Code of Conduct and Global Anti-Bribery and Corruption Policy) when dealing with Company employees
• Report suspected violations of these Ethical Standards

Our Global Inclusion and Diversity Policy and Global Anti-Harassment and Anti-Discrimination Policy, described in the next section, also demonstrate Cushman & Wakefield's commitment to human rights principles and how they're embedded in our operations and business in all stages of human capital management and throughout our operations.

Employment Laws and Policies

Our employees treat each other with dignity and respect at all times. They are expected to exhibit conduct that reflects inclusion during work, at work functions on or off the work site, and at all other company-sponsored and participative events.

Our employees must be on alert for any breach or potential breach of our Global Code of Business Conduct, applicable laws, regulations, or any of our policies and professional standards/regulations. Wherever Cushman & Wakefield's internal policy is stricter than what is required by local law or regulation, employees are expected to follow the company’s stricter policy. All computer-enabled employees are required to take annual training on Cushman & Wakefield Global Code of Business Conduct and any applicable Human Resource trainings.

Starting with the hiring process, Cushman & Wakefield makes employment decisions on the basis of merit. We are committed to attracting, retaining and developing a highly qualified, diverse and dedicated workforce. We hire and promote people on the basis of their qualifications, performance and abilities. Cushman & Wakefield does not discriminate, and does not permit its employees or third parties to discriminate against other employees or applicants because of age, ancestry, citizenship status, color, creed, the requesting, denial or taking of any job-protected and approved Leaves of Absence, pregnancy (which includes pregnancy, childbirth, and medical conditions related to pregnancy, childbirth, and breastfeeding.)

Cushman & Wakefield respects the religious beliefs and practices of all employees and will make, on request, an accommodation for such observances when a reasonable accommodation is available. An employee whose religious beliefs or practices conflict with his or her job, work schedule, or with Cushman & Wakefield’s policy or practice on dress and appearance, or with other aspects of employment, and who seeks a religious accommodation may submit a written request for the accommodation to his or her immediate supervisor who may accept it or offer an alternative accommodation. If for any reason an employee and a supervisor cannot agree on an accommodation plan, our policy is for the employee to appeal by contacting the Human Resources professional aligned to the business segment.

Cushman & Wakefield provides reasonable break time for an employee to express breast milk for her nursing child for up to one year after the child’s birth (or in a timeframe in accordance with the relevant state law) each time such employee has the need to express milk. Nursing mothers will be provided with a place shielded from view and free from intrusion from coworkers and the public. An employee with a private office may use it for this purpose as well. Where an employee has a private office, it may be used for that purpose.

Our Global Anti-Harrassment and Discrimination Policy sets forth Cushman & Wakefield’s belief in treating every employee with dignity. Accordingly, national laws and this policy forbid any unwelcome conduct that is based on an individual’s age, ancestry, citizenship status, color, creed, the requesting, denial or taking of any job-protected and approved Leaves of Absence, pregnancy (which includes pregnancy, childbirth, and medical conditions related to pregnancy, childbirth, and breastfeeding), gender, gender identity or expression, genetic characteristics, marital status, sex, sex stereotyping, national origin, mental and physical disability, race, religion, sexual orientation or sexual preference, genetic information, citizenship, or military or veteran status, including the perception that a person has any of these characteristics or that the person is associated with a person who has, or is perceived to have, any of these characteristics, or any other consideration or characteristic protected by applicable laws. Cushman & Wakefield is thus committed to providing a work environment that is free of unlawful discrimination, including harassment that is based on any legally protected status. Cushman & Wakefield will not tolerate any form of harassment that violates the above mentioned policy.

Employee Resource Groups/Diversity & Inclusion

At Cushman & Wakefield, inclusion and diversity are significant principles, as set forth in our Global Policy on Inclusion and Diversity. The policy asserts Cushman & Wakefield commitment to fostering, cultivating and preserving a culture of diversity and inclusion. Cushman & Wakefield attracts, develops, and retains a diverse, talented, creative, and innovative workforce by fostering an environment that is inclusive at all levels and where each individual feels welcomed, valued, respected and inspired to contribute to the success of Cushman & Wakefield, its business partners, and the global community. Inclusion is a business philosophy and a way of managing and behaving that is embedded in everything we do. Cushman & Wakefield embraces and encourages its employees’ differences in age, color, ethnicity, family or marital status, gender identity or expression, language, national origin, physical and mental ability, political affiliation, race, religion, sexual orientation, socio-economic status, veteran status, and other characteristics that make our employees unique because we know that our human capital is the most valuable asset we have. The collective sum of the individual differences, life experiences, knowledge, inventiveness, innovation, self-expression, unique capabilities and talent that our employees invest in their work represents a significant part of not only our culture, but our reputation and company’s achievement as well.

We maintain an external hotline, EthicsPoint, where employees, clients and third parties can report suspected human rights violations. In addition to the option to report issues through our EthicsPoint Helpline, employees who believe they have been subjected to any kind of behavior that violates their human rights or conflicts with one of our applicable policies can report to their manager or Human Resources representative.

Our teams around the world are championing workplace inclusion through ongoing employee-led initiatives including:

Women’s Integrated Network (WIN)

WIN’s mission is to develop and support women at Cushman & Wakefield by providing a platform that values diverse perspectives and leverages leadership skills to benefit WIN members, our clients and the industry. In 2018, WIN expanded beyond North America with new chapters in Sao Paolo, Melbourne and Singapore, and currently has more than 2,400 active members globally. Last year, WIN piloted its first annual nine-month mentoring program for high-potential, mid-career women in North America that aimed to strengthen Cushman & Wakefield’s culture as a great place for women to work, advance, lead and influence. Twenty mentoring pairs completed the program in this first cycle.

While advancing women in our workplace is a year-round aspiration, we take the opportunity each year on March 8 to celebrate International Women’s Day (IWD) in recognition of the social, economic, cultural and political achievements of women. Our offices around the world participate in this global event each year. In 2018, we invited all employees globally to share their IWD stories in our #PressforProgress social media campaign, and launched a dedicated webpage showcasing stories, photos and videos about the way we #PressforProgress.

Blacks United in Leadership and Development (BUILD)

BUILD fosters the advancement of professionals who identify as black or are of African descent. The group supports career and leadership development, networking opportunities and community service initiatives to help engage, attract and retain top talent at Cushman & Wakefield.

UNITY

UNITY’s mission is to increase visibility and provide an openminded support system for conducting business and addressing the personal requirements of our lesbian, gay, bisexual, transgender, queer/questioning and allies (LGBTQ+) community. The group offers employee development, networking and community service opportunities.

Cushman & Wakefield has established a number of D&I initiatives, but we made significant strides in our LGBTQ+ inclusion efforts in 2018.
• our employee resource group UNITY now has multiple chapters across the U.S. and Canada
• we strengthened employee and management training around LGBTQ+ diversity in the workplace
• We were among the first in our industry to implement preferred gender pronouns (for example: She/Her/Hers) in our corporate email signatures across our global platform.

In recognition of these efforts, we received a perfect score of 100 on the Human Rights Campaign Foundation’s Corporate Equality Index, and qualified as a Best Place to Work for LGBTQ Equality.

In addition to ERGs, we maintain programs and initiatives at the local level that support D&I. For example, the Australia & New Zealand Diversity & Inclusion Network (ANZDIN) was formed in 2018 to advance a respectful, inclusive culture which encourages growth to the fullest potential for Cushman & Wakefield and our people. ANZDIN has partnered with the Diversity Council of Australia, an independent not-for-profit workplace diversity advisor, allowing Cushman & Wakefield to draw on industry best practices, develop and contribute to new initiatives, and continue to welcome a diverse workplace.

INSPIRE is an EMEA-based D&I program dedicated to respecting differences and the nurturing strengths of each individual in our firm. INSPIRE has several committees dedicated to D&I, including Gender, LGBTQ+, Mental & Physical Wellbeing, Work/Life Solutions, Socio-Economic backgrounds and Ethnicity & Culture.

Around the world, we have gained greater awareness of the challenges associated with mental health and learned more about the ways we can support our colleagues who are affected by stress, anxiety, depression or other factors affecting their mental wellbeing. We have organized several programs and activities to address mental health.

Increasingly, wellness in the workplace has become an imperative area of focus in creating a healthy and engaged workforce. Colleagues who are able to manage work and personal priorities with minimal conflict are happier, more productive and rarely absent due to sickness. For Cushman & Wakefield, this means undisrupted, positive service for our clients. We support our employees as they manage work-life responsibilities by providing flexible work arrangements, paid time off for important milestones such as the birth or adoption of a child, and paid leave at more difficult times. Employees can apply Assistance Program that provides childcare, legal, financial, health and wellness support and resources.In Australia, we maintain a partnership with Jobsupport, a specialist employment service that helps people with an intellectual disability find meaningful employment. We currently have five employees through the Jobsupport program who manage our front-of-house facilities in our Australian offices. Cushman & Wakefield’s growing partnership with Jobsupport demonstrates our commitment to diversity and our vision of creating an inclusive, skilled workforce. Additionally, our Cushman & Wakefield office in Brazil is committed to hiring a team that includes employees with disabilities. In the past, the Brazil office has received the Good Practices for Employees with Disabilities Award by the Brazilian State Secretariat for the Rights of Persons with Disabilities.

Cushman & Wakefield maintains an open working environment which includes a safe and easily accessible procedure for all employees to report actual or suspected improper conduct without fear of retaliation.

Additionally, our employees are required to promptly report any accidents, injuries or unsafe working conditions to the appropriate department or manager. At Cushman & Wakefield, we invest in the safety of our facilities and wellbeing of our people so they can do their best work and deliver the best solutions for our clients. Our employees are all responsible for maintaining a safe and secure workplace by following safety and health laws and Cushman & Wakefield’s Health, Safety, Security and Environment policies.

As mentioned above, we maintain an external hotline where employees, clients and third parties can report unethical of illegal activity or suspicion of the same, including suspected slavery or human trafficking in our business or supply chain.

In the event a report is received, we will act immediately and resolutely. This can include working with suppliers to remedy any breaches, but also instantly terminating contracts, reporting to law enforcement and other bodies as appropriate.

Raising questions and concerns reinforces our commitment to act ethically in every business situation. Early detection of potential issues allows the Company to address concerns before they become larger problems, and to take corrective action, if necessary.

We conduct thorough and objective investigations by
• investigating all reports promptly, thoroughly and consistently with applicable law;
• keeping investigations confidential to the extent possible, but may report matters to the appropriate authorities as necessary or proper;
• taking appropriate corrective or disciplinary action for violations of the Global Code of Business Conduct;
not tolerating acts of retaliation (including adverse impact on employment) against anyone who makes a good faith report of a possible breach of the Code, or who participates in an investigation of possible wrongdoing.

Above all, we are committed to maintaining a culture where all employees are comfortable asking questions, speaking up and working toward solutions. We wanted to hear from our employees on these matters, so in 2018, we held our first-ever global engagement survey to better understand our employees’ views about working at Cushman & Wakefield. The survey was offered in 15 different languages, and we received a global response rate of 52%, exceeding our expectations for this first-time initiative. Of those respondents, 92% of global employees said they feel they belong at Cushman & Wakefield.

Employee Policies

For our 51,000 employees across service lines and in more than 70 countries, employee wages, benefits and rights are determined in accordance with applicable international, national, state or local laws, and applicable standards. We have overarching company policies and handbooks on employee rights, safety and responsibilities and their compensation and benefits, including the Global Code of Business Conduct, Global Policy on Inclusion and Diversity, Global Health, Safety, Security and Environment Policy and Global Anti-Harassment and Anti-Discrimination Policy. Additionally, there are country- and service line-specific policies and handbooks to help employees specifically navigate their employment rights.

Globally, Cushman & Wakefield respects the rights of its employees to join labour organizations or refrain from doing so and follows all applicable laws. Cushman & Wakefield also complies with wage and hour laws and fair labour practices for our employees. In the U.S, for example, this includes the Fair Labor Standard Act (FLSA) and Department of Labor requirements, which are reflected in our U.S. Wage and Hour Policy which incorporates legal and regulatory compliance into our policies on wages, overtime, attendance records, payment for standby, call-back and on-call time, report to work pay, “make up” time, travel pay, time keeping and records, rest breaks and meal periods.

Our corporate policies, as provided in our Employee Handbook, also follow FLSA rules on applicable issues including jury duty, time off for voting, religious accommodations, lactation accommodations, employee records, resignations and voluntary terminations.

Involuntary servitude, slavery or practices similar to forced labor have no place in Cushman & Wakefield’s operations. We have zero-tolerance for slavery and human trafficking, and our policies prohibits all forms of forced or compulsory labour. We are also committed to ensuring compliance with all applicable modern slavery laws such as the UK’s Modern Slavery Act 2015. In accordance with this Act, our UK Modern Slavery Act policy requires that in parts of our business where we assess or believe the potential risks of modern slavery to be higher, we use a number of measures to reduce the risk, including:

• using contractual clauses in supplier contracts requiring adherence to our policy’s standards
• conducting due diligence on suppliers for red flags of slavery and human trafficking
• requiring, either expressly or by implication, suppliers to notify us of any breaches

In addition, our policies mandate the adherence to minimum employment age limits defined by law or regulation, and the prohibition of children performing work that exposes them to undue physical risks that can harm physical, mental, or emotional development or improperly interfere with their schooling needs.
We maintain an external hotline, EthicsPoint, where employees, clients and third parties can report suspected slavery or human trafficking in our business or supply chain. Our commitment in upholding section 54 Modern Slavery Act 2015 is achieved by reviewing our Modern Slavery Act policy annually and signing it on behalf of Cushman & Wakefield in the UK.

Supply Chain Policies

Our global supply chain is made up of thousands of suppliers and vendors of goods, services and equipment which support our core business activities. Our Global Vendor/Supplier Integrity Policy sets our expectations in the areas of business integrity, labour practices, health and safety, environmental management, and anti-corruption and anti-bribery. Overall, we engage with suppliers that are aligned with our values and principles and uphold high standards of business integrity and ethical conduct. This is important for our clients, who are increasingly demanding transparency about our supply chain activity, and it minimizes risk to our business.

Our business partners and suppliers are not only held to the high standards of our Global Vendor/Supplier Integrity Policy, but also must adhere to our Global Code of Business Conduct and the company’s other policies and standards referenced therein.

Cushman & Wakefield requires vendors/suppliers to maintain and promote fundamental human rights, where employment decisions are based on free choice without any coerced or prison labour, no use of physical punishment or threats of violence or other forms of physical, sexual, psychological or verbal abuse as a method of discipline or control.

Labour Policies

Cushman & Wakefield encourages employees to raise questions and concerns, helping the company create an ethical and socially responsible work environment. Our Global Whistleblower Policy is in place to:

• encourage employees to come forward and report instances of improper conduct;
• protect individuals that report actual or suspected improper conduct in good faith from any form of retribution, even if the report proves to be unfounded; and
• ensure that all reports are investigated as promptly and thoroughly as possible and that appropriate corrective or disciplinary action is taken.

In the first instance of misconduct, employees may contact local Company management, his/her local/regional legal or compliance representative or human resources representatives when reporting allegations of misconduct. If an employee prefers to raise his or her concerns or report violations anonymously (where permitted by local law), they can do so by contacting the Company’s Ethics Helpline administered by EthicsPoint, an external provider.

In the UK and in regard to the Modern Slavery Act 2015, we routinely train and remind our staff (and where appropriate, suppliers) on their obligations under our policies. Our risk and compliance professionals work with other stakeholders in our business to develop a strategy and approach for training on the Modern Slavery Act 2015.

In 2017, we communicated specifically on the Modern Slavery Act 2015, linking also to the government’s www.modernslavery.co.uk website, forms and resources; the communication and policy are made available to all staff on our intranet, and support is provided by our Legal, Risk & Compliance team.

Employee Health, Safety, Security and Environment

We believe that our colleagues have a right to a safe workplace that protects them from safety risks and hazards. At the same time, they also have a responsibility to perform their work safely, observing all safety policies and procedures, and speaking up to ensure potential safety hazards are identified and eliminated. Cushman & Wakefield is committed to acting in accordance with all applicable safety laws, regulations and our own stringent safety standards in all of our locations around the globe.
Our 360° Health, Safety, Security and Environment (HSSE) Model is based on shared responsibility, collaboration and accountable leadership. Led by a global HSSE team, in line with our global HSSE policy, we strive for continuous improvement in safety performance. We maintain regular safety communications with all colleagues and safety policies and plans are online for employees to freely use. In 2018, we created a single global online safety platform to improve accessibility of all safety resources. Regular hazard identification and risk assessments are performed at several of our sites each year.

To develop and provide quality innovative services that achieve both our HSSE goals and those of our clients, we are committed to:

• Working on the basis that all injuries, incidents and industrial-related diseases are preventable
• Eliminating or reducing hazards and risks by applying control measures that prevent injury or damage
• Consulting with our employees, subcontractors and third parties impacted by our business operations on health and safety matters
• Establishing and achieving measurable objectives and targets, with a focus on continuous improvement in safety, health and wellbeing performance
• Integrating safety, health and wellbeing management into every aspect of our operations as a priority business function
• Verifying that our activities comply with performance requirements and commitments
• Maintaining a safety, health and wellbeing management system in line with International OHS standards and complying with applicable laws, regulations and standards
• Developing safety, health and wellbeing programs that enhance the effectiveness of our leadership, work methods and safe work behavior within our organization
• Providing safety, health and wellbeing training to all employees
• Disseminating safety, health and wellbeing information to all employees, contractors, labour hire employees and visitors to the workplace

Wellness

We know that wellness in the workplace is an imperative area of focus in creating a healthy and engaged workforce. Therefore, we support our employees as they manage work-life responsibilities by providing flexible work arrangements, paid time off for important milestones such as the birth or adoption of a child, and paid leave at more difficult times. Employees can apply for up to 180 days of sabbatical leave for personal reasons, which may include health or study opportunities. We also provide a comprehensive Employee Assistance Program that provides childcare, legal, financial, health and wellness support and resources.. Colleagues who are able to manage work and personal priorities with minimal conflict are happier, more productive and rarely absent due to sickness. For Cushman & Wakefield, this means undisrupted, positive service for our clients.

Additionally, we are dedicated to evolving the built environment to best support human needs and prioritize wellness. As a Founding Alliance Member of the Well Living Lab, we support the advancement of science to generate evidence-based findings through human-centered research to be used in practical ways to create healthier spaces for people. In 2018, we certified two Cushman & Wakefield offices to the WELL Building Standard.

In the UK, under the auspices of our Inspire program, we held a second annual Mental Awareness Week in 2018, providing lectures and activities for employees to hear the personal journeys of colleagues who have overcome mental wellness challenges. Cushman & Wakefield is a signatory to the Time to Change employer pledge to end the mental health stigma. In 2018, our Singapore office developed and issued to all colleagues a Safety Alert on Mental Wellness at the Workplace, raising awareness and offering supportive tips to strengthen mental resilience.

As a business employing thousands of individuals in facility services, we have invested in programs to address the shortage of skilled labour in this sector, including apprenticeships, scholarships, mentoring programs, and engaging with social enterprises. In 2018, through our existing relationship with REDF, a venture philanthropy that invests exclusively in social enterprises that employ and empower people overcoming barriers to work, we joined forces with Cara Chicago, a nonprofit agency that seeks to take people out of poverty by training them for and connecting them to meaningful work. We launched our partnership with Cara through a week-long training program, where eight Cara participants learned to be safe, effective and professional facility services employees.

Diversity and Inclusion

To continue fostering an inclusive company culture that empowers our diverse workforce, Cushman & Wakefield maintains a variety of diversity and inclusion (D&I) initiatives, including:
• Enforcing diverse hiring practices: All our recruitment staff are trained in diverse hiring practices, and our standards require that all hiring for leadership roles must include at least two diverse candidates.
• Maintaining a D&I intranet site: Accessible to all colleagues, this internal site is a hub for information about our D&I philosophy, leadership commitment, trainings, activities and updates.
• Engaging our workforce through Employee Resource Groups (ERGs): Our ERGs offer an internal network for our employees to meet, engage with and learn from people of different cultures, genders, sexual orientations and other common backgrounds.
• Manager Development Program: Our “Building a Respectful & Inclusive Workplace” training is offered to all managers in the Americas to increase awareness, personal accountability and elimination of unconscious bias.
• Measuring employee engagement: We regularly conduct surveys to gauge employee satisfaction and engagement.
• Observing diversity days and heritage months: Colleagues around the world celebrate occasions such as Black History Month, International Women’s Day, Pride Month, Hispanic Heritage Month, Veterans Day and more through ERG participation and local offices events.

Demographics

In 2018, 39% of the Cushman & Wakefield's employees were women, 61% were men and 0.03% employees were non-declared or transgender. In reviewing our employee base by age in 2018, 20% were below the age of 30, 50% were between the ages of 30-50 and 30% were above the age 50 . 65% of management hire in the U.S. were diverse.

Employee Performance Evaluation

In regards to performance management, our philosophy is to establish expectations and a standard practice to:
• Align employee performance with company goals so that every employee and his/her manager agree on how his/her efforts contribute to the achievement of the firm’s objectives
• Provide ongoing feedback and coaching to help employees understand how they are performing, develop skills and competencies, and improve performance over time
• Drive employee engagement through ongoing communication, career growth and connection to the business
• Enable managers and leaders to understand the depth and breadth of talent within their organizations and plan their talent strategy accordingly

Supply Chain

We developed a Supplier Diversity Program that is based on five key elements: i) Supplier identification ii) Performance management iii) Development & mentoring iv) Outreach v) Continuous improvement. In 2018, we completed a first-ever analysis of our supply chain to understand the degree in which we are engaging diverse suppliers by category and spend. We found we spent more than $43 million with more than 8,600 diverse suppliers in the U.S.

Cushman & Wakefield is committed to be a responsible steward of the environment. We continue to seek to identify all environmental risks and opportunities associated with our business including climate change and resource depletion. We are committed to conducting our operations and delivering our products and services with the highest standard of environmental care and social responsibility. To this end, we are committed to a sustainable future, achieving a balance between environmental, technological, economic and social objectives.

Our Global Environmental Policy outlines our commitment to:

• reduce the impact of buildings on global greenhouse gas emissions. Calculate and disclose our carbon footprint from corporate operations, benchmark our performance and set carbon reduction goals.
• undertake our operations and delivering products and services in a manner consistent with, local and regional business requirements and where appropriate the international standard for Environmental Management Systems, ISO 14001.
• conducte assessments of environmental aspects and impacts, as well as set objectives and targets, to reduce waste and impacts on the environment, prevent pollution, conserve natural resources, protect cultural heritage, and drive energy efficiency.
• ensure our operations, products and services comply with applicable legal and other compliance requirements.
• provide appropriate education and training, particularly for our employees with environmental responsibilities, to ensure we meet our environmental objectives and targets.
• make continual improvements in environmental performance, with the aim of protecting the environment.

We recognize that each employee, subcontractor and supplier has a role to play in protecting environmental quality. To achieve our commitments and ensure the effectiveness and success of our approach to environmental sustainability, we:

• demand the involvement of all employees, subcontractors and suppliers
• establish work practices, and conduct monitoring and evaluation, to ensure environmental objectives and targets are achieved
• require suppliers and subcontractors to operate in an environmentally responsible manner and adhere to relevant environmental standards
• regularly review performance, and identify and implement corrective and preventative actions, so as to promote continual improvement in the environmental performance of our operations, products and services, and
• actively provide for, encourage, and support education and training on environmental and sustainability issues.

In order to ensure an ethical supply chain, we aim to engage with suppliers that are aligned with our values and principles and uphold high standards of business integrity and ethical conduct. This is important for our clients, who are increasingly demanding transparency about our supply chain activity, and minimizes risk to our business. We engage with our strategic suppliers on matters relating to social and environmental sustainability, ensuring they understand our Global Vendor / Supplier Integrity Policy, which sets out our expectations in the areas of business integrity, labour practices, health and safety, environmental management, and anti-corruption and anti-bribery.

In developing our CSR priorities, Cushman & Wakefield considered the UN global agenda for 2030 in the form of the Sustainable Development Goals (SDGs), adopted by the United Nations in 2015. The 2030 Agenda is an overarching global plan of action for people, planet and prosperity, with 17 SDGs and 169 associated targets at its core. While many of the goals address the actions and intentions of governments, business has a significant role to play in driving action to achieve the goals. Cushman & Wakefield recognizes five SDGs that have the most material relevance to our business and where we can make the greatest relative contribution:

• Good Health and Wellbeing
• Decent Work and Economic Growth
• Industry, Innovation and Infrastructure
• Sustainable Cities and Communities
• Climate Action

Promoting Community Solidarity

Around the world, we engage in our communities to improve the quality of life and reinforce our deep connections to our local cities and neighborhoods. Although our business is about real estate, our hearts are with the people who live and work in our communities, and we aim to make a tangible positive impact wherever we have a footprint. Our engagement takes different forms and focus around the world, partnering with local nonprofits or community organizations for amplified impact. Throughout our long history, our culture of local community service and engagement has included support for many organizations, including Boys & Girls Clubs of America, Covenant House, Girl Scouts of America, Habitat for Humanity, and Ronald McDonald House, to name just a few. In 2018, we formalized our commitment in the U.S. through our new Cushman & Wakefield Charitable Foundation, providing a more focused and formal channel of strategic philanthropic support. Local initiatives will still continue around the world.

Also in 2018, we announced a new Volunteer Time Policy, which allows employees to use up to two additional days of paid time off each year to volunteer for accredited charitable organizations. The policy creates new opportunities for employees to volunteer, empowering our people to engage in service that is meaningful to them. The policy currently applies to U.S. employees who work at least 20 hours per work and have been employed with our company for at least six months

Adding Sustainable Value in Real Estate

The built environment accounts for more than 40% of global energy consumption and for approximately one-third of the world’s carbon emissions. With this in mind, we aspire to help mitigate the effects of climate change by continuing to advocate for sustainability practice in construction and building occupancy throughout our markets. This is not a hard sell these days – the majority of our clients are already on their own sustainability journey. Green building and sustainable building management are key elements in their journey, and they seek us as a trusted partner to support this transformation.

In 2018, as part of our commitment to sustainable building, we launched our new Smart Building and Green Finance services platform in Greater China. The platform evaluates property value, enhances energy conservation and emission reduction, lowers financing and operating costs, and increases the overall return on investment, enabling our clients to achieve environmental goals while benefiting from financial gains.

We frequently take part in events to advance awareness and knowledge around the future of real estate. In 2018,we partnered with the Singapore Green Building Council to organize a conference, The Future of Buildings, that brought together industry leaders advocating sustainability in the built environment. From carbon neutrality and placemaking in green buildings, to energy efficiency retrofitting, the conference was an opportunity to connect with the community and share our vision of what’s next in real estate.

Helping Clients Go Green

We work with leading standards, such as the U.S. Green Building Council’s Leadership in Energy and Environmental Design (LEED), as well as our own menu of proprietary green practices that we have developed based on our in-house experience and expertise, to help our clients get the most out of their buildings. These practices include:

> Making operational and energy efficiencies to achieve leading green building standards and certifications
> Supporting planning and development of renewable energy installations
> Performing environmental risk assessments and assisting in risk mitigation
> Planning and implementing retrofits for energy and water efficiencies
> Providing technology solutions to monitor and track resource consumption and identify opportunities for improvement

Case studies:

Embedding Sustainable Practices in Singapore

French multinational company Schneider Electric planned to convert an existing nine-story, 20-year-old building into a new regional headquarters in Singapore, targeting a green and sustainable facility. To help realize this objective, our Project and Development Services team in Singapore helped transform the building’s office spaces, delivering an efficient electrical and system design, energy efficient equipment and smart controls – all resulting in a significantly reduced carbon footprint. Schneider Electric employees moved to the new headquarters in time for its opening in March 2018. As an added bonus, Schneider Electric’s new headquarters building was awarded the Building and Construction Authority (BCA) Green Mark Platinum Award, the first office building to be certified under the new BCA guidelines in Singapore.

Helping Adobe Go Above and Beyond

With support from our teams at Cushman & Wakefield, Adobe became one of the earliest adopters of the U.S. Green Building Council’s LEED for Existing Buildings Operations & Maintenance (EBOM) rating system over a decade ago. In 2018, we continued to partner with Adobe by supporting the successful recertification of
five EBOM buildings in three cities at LEED Platinum and Gold levels using the U.S. Green Building Council’s latest innovation in performance measurement, a tool known as Arc. In addition, our team at Adobe developed a multi-year road map of energy efficiency target proposals through 2025 that put Adobe on trajectory to achieve its target of reducing greenhouse gas emissions. The Cushman & Wakefield team applied predictive analytics to forecast times of peak energy demand, and implemented optimization measures to reduce emissions as well as energy costs.

Green Apple Award for Green Building

Cushman & Wakefield’s EMEA Energy, Infrastructure & Sustainability team was presented with an International Green Apple Award for Environmental Best Practice in a ceremony at the UK Houses of Parliament in November 2018. The award recognizes our role in the development and delivery of the UK’s largest shopping center solar photovoltaic (PV) project at The Galleries Shopping Centre in Tyne and Wear, England, owned by M&G Real Estate. The 400-kW system includes 1,317 individual PV panels, covering an area of 41,000 square feet on the shopping center’s roof. Generating around 315,000 kilowatt-hours (kWh) of electricity – enough to power 68 UK households for a year – the project saves around 165 metric tons of CO2 emissions annually. Our teams delivered the development work, financial modeling and project management. The project itself also won a Green Apple award.

Reducing Electricity Consumption

In Washington D.C., Lafayette Centre, a three-building project owned by Beacon Capital Partners (through an affiliate), saved nearly 2 million kWh in 2018 compared to 2017 as a combined result of Beacon’s conservation programs and Cushman & Wakefield’s support in deploying energy conservation measures and increasing building operating efficiency. Efforts included implementing low or no-cost practices such as comprehensive in-house preventive maintenance, making temperature adjustments in line with daily weather, performing after hours inspections to identify and correct unnecessary equipment utility usage and more. The objective was to help Lafayette Centre get the most from its existing equipment and installations – proving that, with consistent, attentive management of resources, major benefits can be achieved for building owners and the planet.

Cushman & Wakefield supports global efforts to mitigate the effects of climate change and strive to maintain the lowest possible levels of energy consumption and resulting greenhouse gas emissions (GHG) in our offices and activities. We generate direct emissions (Scope 1) through stationary and mobile fuel combustion and indirect emissions (Scope 2) through purchased electricity at our office facilities. In the past four years, while our global footprint has grown as we have expanded our business internationally, we have significantly improved our energy and emissions efficiency through ongoing improvements in energy controls, installation of energy-efficient appliances, and employee education and behavioral change. Additionally, we generate GHG emissions through employee business travel and certain distribution losses in fuel- and energy-related activities (Scope 3). Continued efforts to reduce business travel through use of virtual meeting platforms and deployment of local teams in our international markets yielded further improvements in our Scope 3 emissions performance.

We achieved a 26% reduction in global GHG emissions (Scope 1 & 2) per $billion revenue between 2017 and 2018. We achieved a 5% reduction in global GHG emissions (Scope 3) per $billion revenue between 2017 and 2018.

We saw a 13% reduction in absolute GHG emissions (Scope 1 & 2) due to reduction initiatives, including real estate consolidation at our facilities. Scope 1 emissions show an increase across our portfolio due to improved methodology and data quality for stationary combustion in leased office space.

We calculate our greenhouse gas emissions inventory in accordance with the GHG Protocol Corporate Accounting Standard using an operational control boundary. Scope 1 and Scope 2 emissions from all global owned and leased facilities worldwide are included in our inventory. Energy consumption is estimated for leased facilities where we do not have access to actual metered energy consumption data.

We measure and report our Scope 3 emissions from business travel, transmission and distribution losses. Emission factor sources include: U.S. EPA Emission Factor Hub, March 2018, U.S. Electricity: Year 2016 eGRID Subregion Emission Factors (eGRID 2016, February 2018), international Electricity: Year 2011 factors from “CO2 Emissions from Fuel Combustion (2013 Edition)”, IEA, Paris.

Adjustments were made to 2017 reported data following correction of minor discrepancies in fuel accounting from 2017. Our Scope 1 emissions include natural gas and transportation fuels.

In 2018, we were again named an ENERGY STAR® Partner of the Year by the U.S. Environmental Protection Agency and we improved our operational efficiency, reducing global greenhouse gas emissions 26% per $1 billion of revenue between 2017 and 2018.

As one of the world’s leading commercial real estate services firms, we hold ourselves to the highest standards of corporate integrity and strive to create a culture in which everyone acts out of personal accountability for protecting our business, our reputation, our commitments to our Board of Directors, our clients and all those we serve. We aim to uphold all applicable laws and regulations affecting our business around the world without exception and to uphold our own standards of ethical behavior. Our global Ethics and Compliance program is led by our Chief Ethics & Compliance Officer and supported by regional compliance professionals across the globe.

Cushman & Wakefield has zero-tolerance for corruption, bribery and extortion. Cushman & Wakefield’s Global Anti-Bribery & Corruption Policy requires all employees to:
• comply with all applicable anti-bribery and corruption laws and regulations in the U.S., UK and any other jurisdictions in which Cushman & Wakefield operates or does business;
• not offer or make a bribe or improper payment to (or for the benefit of) any organization or person, including a Government Official;
• not accept a bribe or improper payment from any organization or person designed to secure favorable treatment for or from the Cushman & Wakefield;
• not make offers of employment to any person where such offer could be perceived as providing Cushman & Wakefield with an improper advantage or where such offer carries with it an expectation of Cushman & Wakefield receiving favorable treatment;
• not make a Facilitation Payment on behalf of Cushman & Wakefield;
• apply a risk-based approach to anti-bribery and corruption which includes the completion of formal risk assessments where there is a heightened level of bribery or corruption risk;
• conduct appropriate due diligence to verify that a potential third party, joint venture partner or merger/acquisition target company does not present heightened legal, regulatory or reputational risk with respect to bribery or corrupt conduct for Cushman & Wakefield;
• include appropriate anti-bribery and corruption terms and conditions in all new agreements with all parties who act on Cushman & Wakefield’s behalf, including third parties that interact with governments or government officials and all new joint venture partners, affiliates and parties to new merger/acquisition agreements;
• ensure that all fees paid to third parties are for legitimate services and are reasonable in relation to the services rendered; and
• ensure that the Cushman & Wakefield’s books, records and accounts are kept and maintained in reasonable detail and accurately reflect transactions and dispositions of assets.

We do not authorize, tolerate or get involved in any business practice – even if it is “customary” in a particular jurisdiction – that does not comply with our Global Anti-Bribery & Corruption Policy and applicable laws. To the extent any applicable law requires standards that are stricter than the requirements of this policy, the stricter standards are followed.

Our new Global Charitable Contributions and Sponsorships Policy outlines our approach to being a good corporate citizen; we never offer or accept gifts, payments or hospitality to encourage or reward a decision. The policy is a key part of our Anti-Bribery & Corruption Program. Additionally, our commitment to ethical business practices is upheld by incorporating the principles of our Global Anti-Bribery & Corruption Policy in everyday business transactions.

Our Global Code of Business Conduct, published in several languages, defines the conduct expected of all officers and employees of the company. Annual online training and certification to the Global Code of Business Conduct is mandatory for all employees. The Code is updated annually, taking into account new considerations that arise during the year. In 2018, for example, minor adjustments were made to accommodate new language relating to insider trading to align our Code with expectations of Cushman & Wakefield as a newly publicly-listed company.

In order to provide instruction on how to conduct ourselves in an ethical manner and according to law, we maintain several global compliance policies. In 2018, we supplemented these with additional policies governing how we conduct ourselves in different trading scenarios and business relationships. Throughout the year, we engaged all relevant employees in training on these new policies, in addition to ongoing training in all areas of compliance.
• Code of Business Conduct
• Anti-Bribery and Corruption Policy
• Economic Sanctions Policy
• Vendor/Supplier Integrity Policy
• Conflicts of Interest Policy
• Due Diligence Policy
• Whistleblower Policy
• Client Third Party Privacy Confidentiality Policy
• Charitable Contributions and Sponsorships Policy
• Insider Trading Policy
• Global Code of Business Conduct for Members of the Board of Directors
• Policy Concerning Related Third-Party Transactions

We encourage a culture where employees are empowered to speak up to address potential breaches of compliance or expected ethical conduct. We urge employees to report concerns and do not tolerate acts of retaliation against those who do. Confidential reports can be made to local management, a regional legal or compliance officer, human resources managers or through our global 24/7 multilingual Ethics Hotline.

To monitor compliance and identify gaps, we conduct periodic audits and risk assessments of our activities and controls in targeted countries. In 2018, we created a Compliance Risk Assurance Committee with specific focus on ensuring corruption and bribery risks are identified and mitigated.

Through our Enterprise Risk Management Program, we maintain a systematic, disciplined approach to evaluating and improving the effectiveness of governance, internal controls and risk management processes throughout our global operations. We carry out annual Global Enterprise Risk Assessments which include corruption risk. In 2018, key risks included the need to reinforce ongoing vigilance in complying with the U.S. Foreign Corrupt Practices Act (the FCPA), the UK Bribery Act and other anti-bribery, anti-money laundering and corruption laws.

Our business activities are subject to a number of laws that prohibit various forms of corruption, including local laws that prohibit both commercial and governmental bribery and anti-bribery laws that have a global reach, such as the FCPA and the UK Bribery Act. Additionally, our business activities are subject to various economic and trade sanctions programs and import and export control laws, including (without limitation) the economic sanctions rules and regulations administered by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), which prohibit or restrict transactions or dealings with specified countries and territories, their governments, and in certain circumstances, their nationals, as well as with individuals and entities that are targeted by list-based sanctions programs. We maintain written policies and procedures and implement anti-corruption and anti-money laundering compliance programs, as well as programs designed to enable us to comply with applicable economic and trade sanctions programs and import and export control laws (Compliance Programs).