Ethics Helpline

The CBRE Ethics HelpLine is a comprehensive and confidential reporting tool managed by NAVEX that enables management and employees to work together to address fraud, abuse and other misconduct in the workplace while cultivating a positive work environment.

• Our employees are our most important asset. Creating open communication channels promotes a positive work environment and maximizes productivity.
• An effective reporting system augments our other efforts to foster a culture of integrity and ethical decision-making.

Please know that CBRE has a strict non-retaliation policy.

Yes. The CBRE Ethics HelpLine enables you to file a confidential, anonymous report via telephone or the Internet.

The CBRE Ethics HelpLine allows employees to report any violation of our Standards of Business Conduct, CBRE’s policies or the law or other concerns you may have.

When you observe some behavior that you believe violates CBRE's policies or RISE values, we expect you to report it. Ideally, you should bring any concerns to your direct manager or a member of Senior Leadership or the People, Ethics & Compliance or Legal teams. We recognize, however, that there may be circumstances when you are not comfortable reporting the issue in this manner. It is for such circumstances that we have partnered with NAVEX.

We all have the right to work in a positive environment. With that right comes the responsibility of acting ethically and letting the appropriate people know if someone is not acting appropriately. By working together, we can maintain a healthy and productive environment. Corporate misconduct can threaten the very existence of an entire company.

We certainly do. In fact, we need you to report. You know what is happening within CBRE—the good and the bad. You may have initial knowledge of an activity that may cause concern. Your reporting can minimize the potential negative impact on CBRE and our people. Also, offering positive input may help identify issues that can improve corporate culture and performance.

Reports are entered directly on NAVEX’s secure server. NAVEX makes these reports available only to specific individuals within CBRE who are charged with evaluating the report based on the type of violation and location of the incident. Each of these report recipients has had training in keeping these reports in the utmost confidence.

No. The CBRE Ethics HelpLine is a positive aspect of our overall philosophy that allows us to ensure a safe, secure and ethical workplace. You are encouraged to seek guidance on ethical dilemmas, provide positive suggestions or communicate concerns. Effective communication is critical in today's workplace, and this is a great tool to enhance that communication.

We have carefully chosen the best reporting tool to meet our compliance obligations while maintaining a positive reporting environment.

NAVEX does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC(s) to our Ethics HelpLine is available.

If you feel uncomfortable making a report on your work PC, you can use a PC outside our work environment (such as one located at an Internet café or a friend's house) through the Ethics HelpLine secure website. Many choose this option, as NAVEX data shows fewer than 12% of reports are generated during business hours.

A report from home, a neighbor's computer or any Internet portal will remain secure and anonymous. An Internet portal never identifies a visitor by screen name, and NAVEX’s system strips away Internet addresses to maintain anonymity.

The NAVEX’s system protects your anonymity. However, if you wish to remain anonymous, you (as a reporting party) need to ensure that the body of the report does not reveal your identity by accident. For example, "From my desk next to Jan Smith…" or "In my 33 years…".

Yes. You will be asked to provide the same information that you would provide in an Internet-based report, and an interviewer will type your responses into the Ethics HelpLine website. These reports have the same security and confidentiality measures applied during delivery.

The report has a section to identify yourself, if you wish. Please know that we provide confidentiality to all participants who report a concern or participate in an investigation to the extent possible. If you provide your contact information, it will be provided to the investigator.

The subject(s) named in the report will not have access to the report information or your follow-up communications in the Ethics HelpLine or otherwise. Moreover, CBRE will not tolerate retaliation against any employee for making a good-faith complaint to the company regarding potentially inappropriate conduct.

After CBRE receives your report, a member of CBRE’s Trust Function will review and triage it. The case will then be assigned to a team best situated to address your concern.

The investigator from that team will contact you to discuss your concerns in more detail and determine how to proceed.

Serious misconduct is:

• Any activity that could cause significant legal, financial or reputational harm to the company
• Discriminatory, harassing or other serious behavior towards colleagues, clients or anyone who comes to our workplace
• Illegal activity or a serious breach of CBRE policies or standards
• Fraudulent financial reporting

Whether your concern qualifies as serious misconduct or not, you should still report it! Any suspected violation of our policies or the law is promptly, thoroughly and impartially reviewed.

CBRE ensures investigations are conducted in a timely and thorough manner. Each investigation may have unique or complex factors impacting how long an investigation can take. We typically see that investigations take weeks, not days. Trust Function and People team members will work with the appropriate business leader to ensure expectations are discussed, and important milestones are appropriately communicated.

The investigator will first typically contact the individual who brought forward the complaint or concern. The investigator will interview witnesses to the incident or concern as the investigation progresses. Those witnesses may be managers, peers, subordinates and possibly individuals not employed with CBRE. The investigator will contact interviewees because they may have relevant information deemed important to the investigation. The investigator will also interview the subject of the complaint before the completion of any investigation. To maintain the confidentiality of an investigation, the investigator will not disclose to others, without a need to know, the identity of those who participated.

Reporters will be notified following the conclusion of an investigation and briefed on the outcome when appropriate. Please keep in mind that any course of action taken as a result of an investigation may be confidential, particularly if it involves another individual’s personnel information. Thus, reporters will not receive detailed information regarding the action taken as a result of the investigation.

For more information on how CBRE handles investigations, please visit the CBRE Trust Function site.

For CBRE’s Global Policies, please visit the CBRENow Knowledge Library.

We built our reputation as a trusted advisor to clients by following ethical business practices. But that reputation can be diminished or destroyed by the bad acts of just one employee. That is why, in addition to knowing the legal and ethical requirements that apply to your role, you also have a responsibility to bring issues forward. By reporting concerns, you are helping CBRE maintain its reputation and address potential problems before they can negatively impact our company, colleagues and clients.

File a report. NAVEX can help you prepare and file your report so it can be properly understood. We'd rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked.

The NAVEX system and report distribution ensure that implicated parties are not notified or granted access to reports in which they have been named.

When you file a report at the CBRE Ethics HelpLine website or through the Ethics HelpLine Call Center, you receive a unique, randomized number called a "Report Key" and are asked to choose a password. You can return to the Ethics HelpLine by Internet or telephone and access the original report to add more detail or answer questions posed by a CBRE representative. We strongly suggest you return to the site at the specified time to answer any follow-up questions. You and CBRE now have entered into an “anonymous dialogue,” where situations are not only identified but can also be resolved, no matter how complex.

If you report anonymously, please remember to provide all details regarding your concerns. The details should include specific examples of your concerns, dates/times, location and/or any witnesses who may be able to provide additional information.

All correspondences with the CBRE Ethics HelpLine are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity.

To ensure that security and confidentiality are maintained, if you lose your report key or password, you will need to file a new report. Please mention in the new report that it is related to a report or question you previously submitted.

You can file a report with the CBRE Ethics HelpLine from any computer that can access the Internet. You can file from home. Many public locations, including the public library, have Internet computers. If you don’t have access to or are uncomfortable using a computer, call the Ethics HelpLine toll-free hotline, which is available 24 hours a day, 365 days a year.