Cushman & Wakefield Modern Slavery Act statement 

This statement is made on behalf of all Cushman & Wakefield entities and subsidiaries with business interests in the United Kingdom including Cushman & Wakefield Debenham Tie Leung Limited, C & W (U.K.) LLP and C & W Management Services LLP and is pursuant to section 54 of the Modern Slavery Act 2015.  Board approval of this statement was given on 7 July 2022.  

The overall sponsor for this programme is Colin Wilson, our EMEA Chief Executive. 

Our business  
Cushman & Wakefield is a leading real estate services firm in the UK. Our clients are in the public, private, and not-for profit sectors in the UK and globally. We are committed to reviewing and strengthening our processes and systems to minimize the risk of modern slavery in our supply chain. We require all our suppliers to provide services in a responsible manner. 

Our Policies in relation to modern slavery 
Our Compliance policies are designed to enable us to conduct business in an ethical and transparent manner and to make clear the standards expected of our employees and suppliers.  

The leadership at Cushman & Wakefield have tasked the Legal, Risk & Compliance team to monitor compliance with our policies in this area. These policies include:  

Global Code of Business Conduct   
Cushman & Wakefield promotes human rights by upholding the UN Global Compact in our business practices. We conduct business 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 we operate  
  
  
• 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 labour  
  
  
• Prohibit use of child labour  

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.  

Involuntary servitude, slavery or practices similar to forced labour have no place in the Company’s operations. The Company has zero-tolerance for slavery and human trafficking, and Cushman & Wakefield policy prohibits all forms of forced or compulsory labour. We are also committed to ensuring compliance with all applicable modern slavery laws.   
 
Global Due Diligence Policy  
Cushman & Wakefield will only conduct business with reputable clients, business partners, agents, vendors and suppliers and implements due diligence procedures to address risks, including modern slavery risks.   

Global Vendor/Supplier Integrity Policy  
Cushman & Wakefield acts ethically and responsibly because it is the right thing to do. The business practices and actions of our vendors and suppliers reflect upon the company, its reputation and brand.   

We developed vendor and supplier Business Conduct Principles to clarify our expectations in the areas of business integrity, labour practices, health and safety, and environmental management. Vendors and suppliers who do business with Cushman & Wakefield or act on behalf of the company or its clients shall follow these principles.   

Violations of our Business Conduct Principles will result in a review of our business relationship, up to and including, termination of that relationship in accordance with our contractual rights and applicable law.  

Global Whistleblower Policy  
In order to promote an ethical and socially responsible work environment, Cushman & Wakefield’s Global Whistleblower Policy encourages staff to speak up and raise questions and concerns including those concerning modern slavery. The policy also outlines how we protect individuals that report their concerns. 

Managing Modern Slavery Risk 
In addition to our policies, we also take action in all areas of our business, in order to reduce the risk of modern slavery.  

• Supplier Due Diligence - Conducting due diligence on suppliers for red flags regarding slavery and human trafficking.  
  
  
• Contractual Clauses - The use of contractual clauses in supplier contracts requiring adherence to our policy standards, including right of termination if a supplier does not adhere to policy standards or fails to notify Cushman & Wakefield regarding any breaches and the express requirement on suppliers to notify us of any breaches.  
  
  All Facilities Management suppliers must agree to comply with the Cushman & Wakefield Global Vendor/Supplier Integrity Policy. Within our UK business, standard terms and conditions are in place where all suppliers engaged in the course of providing services are required to comply with applicable laws prohibiting modern slavery, including the UK Modern Slavery Act 2015.  
  
  It is critical that our suppliers acknowledge and understand our strong and uncompromising approach to modern slavery 
  
  Cushman & Wakefield carries out systematic screening of our supply chain for adverse media and broader compliance risks. We use a globally recognized compliance screening platform to screen all new suppliers as part of the onboarding process.  Any items of concern are escalated to the Compliance team for analysis and remedial action, as appropriate. Through the due diligence processes that have been implemented in various areas of our organization, we are increasingly able to identify and manage potential risks of modern slavery activities in our supply chain. By being able to identify red flags early, we can either avoid engaging questionable prospective suppliers or, in the case of existing suppliers, work with them to remediate their practices or terminate their services if necessary.  
  
  
• Global Ethics Helpline - We maintain an ethics helpline (EthicsPoint), administered by an external provider, where employees, clients and third parties can confidentially report suspected slavery or human trafficking in our business or supply chain.   
  
  All reports are independently recorded by an external third party and are vetted and overseen by the Compliance Team. 
   
  
• Training & Communication - We routinely remind our staff (and where appropriate, suppliers) of their obligations under our Code of Conduct and Legal & Compliance policies including adherence to section 54 of the Modern Slavery Act.  

Modern Slavery Risk Assessment: During 2021/22, we conducted a risk-based review of our UK suppliers, looking at supplier spend categories and identifying the highest risk categories in relation to modern slavery, as follows:  

• Facilities Maintenance 
• Recruitment Agency Fees 
• Cleaning 
• Recruitment Services 
• Food Services 
• Construction In Progress 
• Temporary Labor - Agency  
• Movers & Relocation 
• Catering 

Within each category, we identified the suppliers by total spend and undertook additional and enhanced due diligence for each. We verified whether our suppliers had their own Modern Slavery Act statements where required. 

Looking ahead 
To date, we have not identified or been informed of any instances of slavery and 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 and reporting to law enforcement and other bodies as appropriate.   

Our goals for 2022 include: the adoption of and adherence to any updates in UK legislation; continue to work on raising awareness across the business; evolving best practices; and implementing internal activities for specific, higher risk business groups. We have identified the following opportunities to increase the impact of our efforts, specifically: expanding training; and continuing to develop supply chain monitoring.