CBRE NI – Anti-Slavery Policy
CBRE NI’s (the Company) supply chain is critical to our success. We require all of our suppliers to provide services in a responsible manner. We have a zero-tolerance approach to modern slavery and are committed to consistently reviewing and strengthening our processes and systems to minimise the risk of human rights infringements anywhere in our supply chain.
This statement has been written in accordance with the requirements of The Human Trafficking and Exploitation (Criminal Justice and Support for Victims) Act (Northern Ireland) 2015 which provides a robust legal framework in respect of the prosecution of perpetrators of modern slavery in Northern Ireland; the provision of improved support for victims; and tackling the demand for the services of trafficked victims.
The policy also takes into account requirements under the UK Modern Slavery Act 2015 (“The Act”). The Act requires that businesses with a turnover of more than £36 million disclose information regarding their policies and actions to eradicate modern human slavery and trafficking from their operations and supply chain. Nevertheless, the Company endorses the aims and objectives of the Act. The Company is also conscious of its obligations under its Affiliate Status agreement with CBRE Group, Inc (CBRE Inc.) and notes its commitment to complying with Anti-Modern Slavery across its global business.
CBRE Inc., is a Fortune 500 and S&P 500 company headquartered in Dallas, is the world‘s largest commercial reaI estate services and investment firm (based on 201 9 revenue). CBRE Inc has more than 100,000 employees (excluding affiliates) and serves reaI estate investors and occupiers through more than 530 offices (excluding affiliates) worldwide. CBRE Inc offers a broad range of integrated services, including facilities, transaction and project management; property management; investment management; appraisal and valuation; property leasing; strategic consulting; property sales; mortgage services and development services.
ORGANISATION’S STRUCTURE, ITS BUSINESS & ITS SUPPLY CHAINS
The supply chains the Company operates are dominated by our Property and Facilities Management (P&FM) operations with significant levels of spend in hard and soft services such as maintenance, cleaning, security, utilities and catering services. In addition to these main spend areas the Company’s supplier spend profile also includes technology and data, marketing services, HR services, professional services and travel.
POLICIES IN RELATION TO SLAVERY & HUMAN TRAFFICKING
The Company is actively working to ensure that modern slavery and human trafficking is not taking place across its business and has policy documents in place to make it clear what standards are expected of our employees and our suppliers.
The Company’s Standards of Business Conduct set out the ethical standards which must be upheld by all staff across our business activities. The document acknowledges that the Company exists and succeeds due to the trust that has been earned for integrity and fair dealing. The Company’s RISE value of Integrity requires that the business always “takes the high road” and deals fairly and honestly with all employees, business partners, communities and society at large.
As such, no one representing the Company will take unfair advantage of anyone through manipulation, fraudulent inducements or concealment, abuse of confidential or privileged information, interference with a known contractual relationship or any other unfair dealing.
No monetary benefit is worth conducting business in this manner. Any profit or gain based on disregarding our values is temporary and causes more harm in the long run. We respect the contracts and commitments we have made and strive to go beyond minimum compliance with the rules governing our business and to operate with the utmost reliability and transparency.
HUMAN RIGHTS POLICY
This policy commits the Company to respect human rights in its operations, to promote an appropriate example and make a positive global impact. The Policy’s four key elements with respect to modern
slavery and human trafficking are as follows:
i. The Company respects the free choice of all persons and strictly prohibits forced or compulsory labour for any employees.
ii. The Company will not do business with, tolerate, or associate with organizations or entities that condone or are engaged in the practice of coercing or imposing of work with little or no freedom
of choice.
iii. The Company endorses the UN Guiding Principles on Business and Human Rights and will work to raise awareness within our employee population of our responsibility to protect Human Rights.
iv. The Company commits to cooperate with law enforcement authorities to address any such instances that come to the attention of the Company.
SUPPLIER CODE OF CONDUCT
This Code sets out the Company’s fundamental ethical and business conduct requirements for its suppliers. It makes clear that a Company supplier is responsible for ensuring its directors, officers,
employees, agents, representatives, suppliers, subcontractors, and other business partners understand, and comply with, the requirements set forth in the Code. The requirements include CBRE NI’s position on Anti-Bribery and Corruption, Unfair Business Practices and a specific section pertaining to Labour standards, including:
i. Child Labour
ii. Human Trafficking, Slavery and the Right to Voluntary Labour
iii. Freedom Against Prejudice and Discrimination
iv. Safe and Secure Workplace
v. Working Hours and Wages
PARTS OF THE COMPANY’S BUSINESS AND SUPPLY CHAINS WHERE THERE IS A RISK OF SLAVERY AND HUMAN TRAFFICKING TAKING PLACE
The Company’s P&FM service line has an extensive supply chain, whereas many other services provided by the Company tend not to work regularly with suppliers. Our P&FM services engage various hard and soft services such as maintenance, cleaning, security, utilities and catering services.
We believe that services reliant on relatively low-paid labour are the Company’s greatest risk areas for abusive and exploitative practices in the supply chain. Examples of the risks we are aware of:
• Cleaning – Subcontracting of old or inappropriate vendors, compliance with minimum wage requirements, excessive hours, poor documentation and no proof of back pay / holidays, risks of noncompliance with social security commitments.
• Catering — Undisclosed subcontractors, workers working under student visas, workers deprived of normal employment benefits, excessive working hours, vulnerable to visa conditions, poor command of local language.
• Security — Underpayment, overtime rates not in line with contract, preventing staff from taking sick leave or annual leave.
The Company recognises that the highest risk areas are outside the UK and that collaboration throughout the supply chain is needed to prevent such issues from a rising. A critical measure for the effectiveness of our program will be the completion of awareness training for our broader employee population, and/or for targeted groups of professionals in specific service lines, support functions or geographies.
TRAINING ABOUT SLAVERY AND HUMAN TRAFFICKING AVAILABLE TO EMPLOYEES.
The Company’s annual SoBC certification is the cornerstone of it’s commitment to ethical business practices. All employees are required to certify they understand and will abide by our SoBC and core policies. The Company’s Human Rights Policy is incorporated into this mandatory process. The Certification process provides the opportunity for staff to disclose any exceptions they were aware of. All employees are required to undertake regular training around this topic also.
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