CBRE NI – Anti-Corruption, Fraud & Bribery Policy
CBRE NI (the Company) has adopted an Anti-Corruption, Bribery & Fraud Policy to document our clear intention to conduct all of our business in an honest and ethical manner. Oversight of this Policy and the Company’s internal controls regarding corruption, bribery & fraud including the authority to report matters to the Executive Management team (EMT) and/or external law enforcement, is the duty of the Quality Manager who shall have an adequate level of autonomy from management and shall be given sufficient resources and authority to carry out this responsibility. This Policy applies to the Company and all employees and should be read in conjunction with Standards of Business Conduct (SoBC).
Responsibility for compliance with this Policy and the related internal controls, ethics and compliance programs or measures is the duty of individuals at each level of the Company. The Company will endeavour in good faith to use its influence to the extent reasonable under the circumstances to require entities not controlled by the Company but which operate on behalf of Company and/or under the CBRE brand (e.g., Representatives) to adopt and implement policies and internal controls of their own that minimise the risk of violation of the anti-corruption & bribery laws relating to the Company’s business.
We take a zero-tolerance approach to corruption, bribery, fraud or other financial irregularity and we are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate, and in implementing and enforcing effective systems to counter any acts of bribery or corruption. We will uphold all laws relevant to countering bribery, corruption and fraud and as a regulated RICS company we will ensure we act to the guidance and standards as per the institution.
Definitions
Bribe: Any payment, gift, promise or offer of money or anything of value, whether directly or indirectly through intermediaries, to any person or entity for the purpose of (a) improperly influencing any act or inaction, or decision or non- decision of the recipient in his or her official capacity, (b) inducing the recipient to act or refrain from acting in relation to the performance of their duties, (c) securing improper advantage, (d) obtaining or retaining business, (e) inducing the recipient to use influence with a third party (including a Government Entity) to affect or influence any act or inaction, or decision or non-decision of such third party, or (f) “rewarding” a recipient after the fact for affecting or influencing any act or inaction, or decision or non-decision of a third party.
CBRE NI Personnel: All Company employees and any individual or entity acting for or on behalf of the Company, operating in any part of the world. CBRE NI personnel shall include temporary or seconded personnel, whether or not employees, who are also employees of third party agencies.
Facilitating or Grease Payment: A small payment made to a Government Entity in order to encourage or reward it before, during or after the fact to expedite a non-discretionary, routine governmental task that it is otherwise required to undertake, such as processing government paperwork, while providing routine government services. Examples of Facilitating or Grease Payments include small fees to receive police protection, mail pick-up, a stamp of an entry visa, or to have a telephone line installed or an application processed. Routine governmental action does not include (1) a decision by a foreign official to award business to, or to continue business with, a company, or (2) an action or inaction, or decision or non-decision to which the Company is not legally entitled.
Fraud: Any activity that relies on deception in order to achieve a gain. Fraud becomes a crime when it is a “knowing misrepresentation of the truth or concealment of a material fact to induce another to act to his or her detriment. Internal Fraud is fraud committed against an organisation by someone employed by that organisation.
Government Entity: A government, government body or department, government employee, representative or official, public official, political candidate, political party, party official, public international organisation (e.g., United Nations or World Bank), a state owned entity (SOE) and every employee of a SOE regardless of rank or title and regardless of how local law may characterise the employee. The term Government Entity should be interpreted broadly and may also include individuals in unpaid or honorary government positions, including committees, panels, commissions or other advisory positions.
Intermediary: A person that contacts or interacts with a Government Entity on behalf of a third party, including a client (e.g., obtaining permits, licenses, occupancy certificates, government data, planning approval, building approval, building completion certificates, fire and safety certificates etc.).
Kickback: A particular form of Bribe which takes place when a person entrusted by an employer or Government Entity has responsibility for the granting of a benefit (e.g., awarding a contract) and does so in a way that secures for his or herself a return (kickback) of some of the value or benefit of that transaction without the authorization of his or her employer or Government Entity.
Quality Manager: The manager responsible for the implementation and continuous improvement of the quality assurance measures for the Company.
Representative: Any person or entity acting on the Company’s behalf for the purpose of developing or securing new business opportunities, retaining existing business opportunities or assisting the Company or a client to obtain a license or approval from a Government Entity. Representatives may include finders, introducers, certain consultants, agents, co-brokers, referring brokers, joint venture partners and Company affiliates or licensees.
SOE: State-owned or state controlled commercial enterprises, which are companies over which a Government Entity exercises substantial control (even if not wholly owned) and are therefore deemed an “instrumentality” of the Government Entity.
Provisions & Conditions
Compliance with Laws
Neither the Company nor any Company employees may, directly or indirectly, break or seek to evade UK or Northern Ireland corruption, fraud or bribery laws or regulations.
Bribes and Kickbacks
Neither the Company nor any Company employees may, directly or indirectly, authorise, offer, provide, solicit or receive a Bribe or Kickback for its own account or as an Intermediary or agent of a CBRE NI client and all offers of, or solicitations or demands for, Bribes and/or Kickbacks must be expressly rejected. This provision prohibits Bribes and Kickbacks to Government Entities, commercial entities and individuals. The Company will take reasonable steps to prevent Representatives acting on its behalf from violating this provision.
CBRE NI Acting as an Intermediary with a Government Entity
If the Company is expected by a client to act on its behalf as an Intermediary with a Government Entity, the contract with the client should be clear as to the scope of services, and any payments or subcontracts undertaken in furtherance of the assignment shall be approved by the SMT. The Company and Company employees shall under no circumstances act as a conduit to pass-through a Bribe, Kickback or Facilitating or Grease payment either on its own or via a third party on behalf of a client. Any Company employee found to have been directly, indirectly or complicit in engaging in such prohibited conduct shall be subject to disciplinary actions, up to and including termination.
Client Transactions with Government Entities (Including SOEs)
The Company shall make best efforts to identify all client transactions to which a Government Entity (including a SOE) is a party and to submit such transactions to the Quality Manager for review for compliance with this Policy.
Facilitating or Grease Payments
The Company prohibits Facilitating or Grease Payments in all circumstances. Such payments are prohibited under NI and UK law. Facilitation payments are prohibited under our company policies. All employees, contractors, and third parties acting on behalf of the organisation must refrain from making or accepting facilitation payments. Regular risk assessments will be conducted to identify and evaluate the risk of facilitation payments within our operations and activities.
All employees will receive mandatory training on the prohibition of facilitation payments, including how to recognise and resist demands for such payments. Employees are encouraged to report any requests or demands for facilitation payments through the established reporting channels. Reports will be treated confidentially and investigated promptly, with appropriate actions taken against those involved in making or accepting facilitation payments. Due diligence will be conducted on third parties to ensure they comply with our anti-corruption policy, including the prohibition of facilitation payments. Contracts with third parties will include clauses that explicitly prohibit facilitation payments and outline the consequences of non-compliance. Internal accounting controls will be implemented to detect and prevent facilitation payments. Employees who encounter demands for facilitation payments should refuse and report the incident immediately.
Charitable and Political Contributions
The Company prohibits any charitable or political contribution to any entity, including at the request or suggestion of a Government Entity (or a family member of a Government Entity employee), in order to gain an improper business advantage. Neither the Company nor any Company employee may authorise, make or reimburse any charitable or political contribution relating to the Company’s business unless it (1) is approved by the Quality Manager or member of the EMT in compliance with the applicable written policy, (2) is legal in the UK, and (3) is properly recorded in the books and records of the Company.
Travel, Meals, Entertainment, Client Events and Gifts
This Policy does not prohibit reasonable expenditures for travel, meals, entertainment, client events and gifts and similar or related expenses of a Government Entity with a bona fide and documented business purpose. Such expenditures made to or on behalf of a Government Entity are prohibited unless they are (1) approved by the Quality Manager or member of the EMT in compliance with the applicable written policy, (2) legal in the UK, and (3) properly recorded in the books and records of the Company. In addition, for any Company function for which any travel or lodging is paid by the Company, the attendance of any Government Entities must be approved in advance. With respect to business travel with any client or third party, the Company will not provide any advances, reimbursements, or per diem or “walking around money”.
Cash Advances
Cash advances to Company employees must be approved by the EMT.
Hiring Employees or Family Members of Clients
From time to time the Company may offer placements, employment or similar positions to employees or family members of clients. However, all hiring decisions should be made on the merits, and be based on the qualifications of the candidate for the position, and making any such offer in order to gain an improper business advantage is strictly prohibited. In addition, the Company will not offer placements, employment or similar positions to a Government Entity or a family member of a Government Entity employee without advance approval.
All Payments/Transactions Must Be Approved
Even if the exact type of payment or transaction is not specifically described here, any payments or offers of anything of value for any purposes to a Government Entity, must be approved in writing by the Quality Manager or member of the EMT and recorded accurately in the Company’s books and records.
Books, Records and Due Diligence
Company Accounts
The Company shall maintain complete and accurate financial records, ensuring that all transactions are properly, accurately and fairly recorded in its books and records. The book entries must be clear and accurate. Obscuring or euphemistic language must be avoided. The obligations above shall apply to all client financial records and accounts managed by CBRE NI.
Relationships with Representatives
Selecting and Vetting Representatives: To minimise the risk that the Company will be held responsible for unauthorised actions of Representatives that violate the anti-corruption, fraud & bribery laws, before engaging any Representative the Company will satisfy itself of the potential Representative’s relevant expertise and good professional standing, that the Representative is not a Government Official, and is not a related party of or directly or indirectly employed by an existing or prospective client. It is a violation of this Policy to engage a Representative on behalf of a client to execute a coordinated scheme to divide a payoff or mutual benefit. In addition, with respect to Representatives that are likely to interact with a Government Entity on the Company’s behalf, the Company will engage in and document due diligence regarding the Representative’s background. This due diligence shall be designed to reasonably gauge the level and nature of anti- corruption, fraud & bribery risk posed by the Representative, as determined by the EMT. Minimum due diligence standards (including checklists) will be approved in advance by the EMT.
Contracts with Representatives: The Company has an obligation to be knowledgeable about the activities undertaken by Representatives on the Company’s behalf and shall have written contracts with these Representatives. Contracts with Representatives that are reasonably likely to interact with a Government Entity are to be reviewed and signed by an Authorised Approver, and shall contain a set of standard representations, warranties and covenants in a form approved by the EMT.
Follow-up on Representatives: Once the contractual relationship commences with a Representative, the Company will monitor the Representative’s performance to satisfy itself that it is in accordance with the contract. This may include communications, certifications, periodic performance reviews, and audits. The Company should encourage Representatives to document their days of work, research and analysis, project staffing levels, travel and other expenses incurred on Company projects. Documentation of these procedures and other information collected during the contractual relationship should be retained for not less than five years after the relationship has concluded.
Recommending Third Parties to Clients: No Company employee shall make a referral or recommendation to a Company client of a third party if the Company employee knows or should know that such third party would likely pay a Bribe or Kickback on behalf of the Client.
Red Flags in Relationships with Representatives: Standard procedures and contract terms, however, are no substitute for our employees’ personal business judgment. There are certain “red flags” that indicate a relationship with a Representative may cause the Company undue risk under the anti-corruption, fraud & bribery laws. (See Appendix A for examples of “red flags.”) . If any red flags are identified, they must be further investigated and resolved and any relationship with such Representative must be approved in writing by the EMT in addition to the Authorised Approver.
Auditing and Monitoring
The Company shall periodically audit and monitor compliance with this Policy. Company employees and Representatives may be required to execute certifications of policy compliance. The company is also externally audited annually, to assess compliance in all areas of quality management including anti- corruption, anti-fraud and anti-bribery processes. To ensure the effectiveness of our anti-bribery, fraud and corruption processes the following key metrics will be regularly reported to senior management:
Number of Reported Incidents
Investigation Outcomes
Disciplinary Actions
Training and Awareness
Internal Audits and Reviews
Whistleblower Reports
Continuous Improvement
Updates to policies and procedures to enhance anti-bribery measures
Risk Assessment
The Company shall conduct periodic risk assessments to assess changing conditions in the market, lines of business and ongoing relationships with third parties, affiliates, and the like.
Hiring/Employing
To mitigate the risk that authority will be vested in a person not trustworthy to act responsibly, the Company should conduct reference and/or background checks, in a manner determined by the EMT, on all candidates for management positions (including property managers) or certain other positions as may be determined by the EMT.
Disciplinary Action
Any employee who violates the law, this Policy or any related policy or procedure may be subject to appropriate disciplinary action, up to and including termination. In addition, the Company may choose or be required to report violations to law enforcement or other regulatory agencies, and the Company employees should be aware that individuals are held personally accountable under the anti-corruption, fraud & bribery laws.
In determining the appropriate disciplinary action, the Company will take into consideration the circumstances under which an improper payment was made (e.g., whether there was a good faith belief that the Company employee’s personal safety was threatened or under the threat of physical violence or incarceration, whereby such payment made under a genuine threat is promptly reported to the Company) consistent with the provisions of this Policy.
Communication and Training
The Company will periodically issue written communications to employees in order to promote awareness of and engagement with, as well as demonstrate top-level commitment to, this Policy. An appropriate level of anti-corruption, fraud & bribery training will be provided to employees and Representatives based on a risk assessment of needs relative to job function, with additional training offered for higher risk employees.
January 2026 v5