CODE OF CONDUCT AND COMPLIANCE RULES

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COMPANY HANDBOOK

Standards of Business Conduct

You must at all times conduct yourself in accordance with the Company’s Standards of Business Conduct. It is important that all employees read, understand and adhere to the CBRE Standards of Business Conduct Manual. In addition, the CBRE Anti-Corruption Policy and supplemental policies should be read in conjunction with the Standards of Business Conduct.

To view the CBRE Standards of Business Conduct Manual please click here

To view the Standards of Business Practice intranet page please click here To view the CBRE Ethics Helpline telephone numbers please click here To view the CBRE Anti-Corruption Policy please click here

To view the Anti-Corruption supplemental policies please click here

CBRE House rules

Details relating to conditions of employment are set out in your contract of employment. It is important that you are fully aware of your rights and obligations as an employee. If you have specific queries you should speak in the first instance to your Manager.

Outside Interests & Secondary Employment

Any existing directorships in public or private companies and formal appointments as a property adviser or consultant must be registered with the Chief Compliance Officer. No new such appointments may be accepted without the prior written approval of the Managing Director.

Any additional employment outside the Company, e.g. working in a pub/restaurant at weekends, may be permissible but needs approval from Human Resources. It is important that this does not have a detrimental effect on your work here.

During your employment, you may not undertake any other paid or unpaid employment outside working hours nor have any interest whatsoever in any business or undertaking or engage in any activities which might interfere with the performance of your duties or cause a conflict of interest or which might be regarded as competing with the legitimate business interests of the Company or otherwise, without the prior written permission of the Company’s Managing Director.

Gifts and Corporate Hospitality

In compliance with the Standards of Business Conduct and the Anti-Corruption Policy, you may not offer gifts or benefits in kind to, nor accept them from, clients, applicants or third parties which could, rightly or wrongly, be construed as an inducement to channel business to them/from them. The Anti-Corruption policy and supplemental policies are available by clicking this link

Gifts and corporate hospitality of a routine/low value nature can be given or accepted, but anything of more than nominal value should be refused.

Any queries regarding this must be referred to the Chief Compliance Officer at an early stage. Failure to comply with the house rules above may result in disciplinary action.

COMPENSATION & BENEFITS

Salary

Details of your remuneration are outlined in your contract of employment. Salary details are confidential and should not be discussed with other employees.

Your salary is paid on the 25th of each month after deductions for income tax and PRSI have been made. You will receive your net pay each month by bank transfer. You can download your payslip directly from MyCBRE.

If you change your bank account, You will need to update these details via MyHR and MyFinance. In addition, you will need to send your bank details directly to the People Team to ensure this is updated for payroll purposes. Payroll cut off is the 10th of every month so please ensure to send the bank details before this date.

Our Payroll is outsourced to a Payroll Services provider, Zellis. If you have a query regarding your salary please speak to The People Team in the first instance.

SALARY REVIEW POLICY How often do they occur?

Salaries are reviewed annually in Q2, taking into account both market factors and individual merit, however, no increase in salary is guaranteed or implied by the review. Employees on any form of notice, be it of the Company’s or the employee’s volition, are not entitled to a salary review. If a salary increase has been confirmed, this will be process in April's pay run.

Bonus Policy

Bonuses are based on the profit and loss performance of the company. The payment of a bonus is at the total discretion of the Company and is subject to the overall availability of profit from CBRE and its parent company, CBRE Inc.

The amount of any individual bonus is at the absolute discretion of the Company, and payment of a bonus one year does not confer or imply any right to receive any bonus the following or subsequent years, nor to receive a bonus of an equivalent amount.

The Company has the right in its absolute discretion to amend, withdraw or replace the scheme at any time and for any reason. While the Company will try to avoid amending, withdrawing or replacing the scheme during the course of any year, the interests of the business may require it to do so. The Company reviews its incentive schemes annually and there is no right or expectation that any particular scheme will operate in future years.

Key conventions apply:

▪ All debts invoiced during the year must be due from the client. The invoicing test to determine when invoices should be issued is that either the valuation report has been issued to the client, legal closing for the transaction has occurred or the contract has become unconditional.

▪ Prior year debtors must be collected by a pre-determined date in March.

▪ Bonuses are paid in April of each year. Should all prior year debtor accounts not be collected by the pre-determined date in March part or all of the bonus may be withheld pending collection of the debtor account.

▪ In order to be eligible for a bonus, you must not be deemed to have resigned, be serving your notice or have left the company at the time the payment is due.

▪ Employees who are awarded a bonus of €25,000 or more and resign between 31 March and 31 July will be required to repay to the Company 100% of the net total bonus payment received. Employees who are awarded a bonus of €25,000 or more and resign between 1 August and 30 September will be required to repay to the Company 50% of the net total bonus received. Repayment in full must be made to the Company within one month of their resignation or termination, whichever is the sooner.

Retirement Age

The company’s normal retirement age is 65. You and your manager will be notified by HR two years prior to this milestone. Circumstance may arise where you wish to continue working past retirement age. Your employment can be continued on a fixed-term contract basis if you and your manager mutually agree for you to continue working. A new contract will be issued and reviewed when you approach the contract end date.

Employee Assistance Programme

As an employee of CBRE you have access to an Employee Assistance Programme. The EAP service with Spectrum Life is a completely free & 100% confidential service, Accessible 24/7, 365 days a year. The EAP can help with a wide variety of personal or work related issues you might be facing e.g. family problems, marital problems, financial worries, stress etc. Click here for contact details.

CBRE has partnered with the Beacon Hospital to provide our employees with ‘Healthcheck’, an advanced consultant delivered, health screening service. With ‘Healthcheck’ you will be tended to by an experienced multi-disciplinary team including consultants, nurses, cardiac physiologists and radiographers all with access to the latest in diagnostic technology.

The Company provides medical screening to employees who have 3 or more years’ service. They will be entitled to the following:

▪ Those over the age of 50, will be entitled to a health screening on an annual basis

▪ Those in the age category of 40-50 years, will be entitled to a health screening once every two years

▪ Those under the age of 40, will be entitled to a health screening once every three years

A detailed, personailised written report including interpretation of results, behavioral and lifestyle modification advice, will then be sent to you as a follow up after your consultation. A copy of this report will also be sent to your GP within 10 days.

Before booking an appointment, please ensure that you have approval from the People Team.

A ‘Healthcheck’ consultation with the Beacon hospital will take approximately 3.5-4 hours. To make an appointment, please call the Beacon on 012936090 or email them on healthcheck@beaconhospital.ie

For further information on additional health checks and terms & conditions, please click here.

CHANGE OF PERSONAL INFORMATION

It is your responsibility to update MyHR with any changes to your personal information, such as change of address (include postal code), marital status, name, bank details, and various other details. You can access Personal Details though MyCBRE. If you are unable to change this information in MyHR please contact the HR Department.

HOLIDAYS/LEAVE

Holiday Entitlement

Details relating to annual holiday entitlement are set out in your contract of employment but in general, the following rules apply:

The firm’s holiday year runs from January to December. Holiday entitlements are given in accordance with the provisions of the Organisation of Working time Act, 1997. Please see below:

1) Entitlement to annual holidays is linked to the number of weeks worked in any calendar year. You may qualify for leave according to the following methods:

Where you work at least 1,365 hours in a leave year, you are entitled to 4 working weeks (i.e. 20 days) annual leave. If the number of hours you work is less than 1,365, annual leave must be calculated on a monthly basis as follows:

Where you work at least 117 hours in a calendar month, you are entitled to 1/3 of a working week for that month.

Where the hours you work are less than 117, you are entitled to 8% of the hours you work in the leave year, subject to a maximum of 4 working weeks per annum

2) In addition to annual entitlement you will have 10 statutory days holidays, as follows:

3) In addition the company closes on Good Friday (not a public holiday) and for additional days during the Christmas holiday period which are not covered by statutory holidays. These days are given by the company as additional leave i.e. you will not be required to retain days from your annual leave entitlement to cover these holidays. In Q3 a comms will be sent to all employees outlining the confirmed Christmas Company Days.

When arranging annual holidays you should be aware of the following:

▪ All holiday dates are subject to the prior approval of your manager. You must obtain authorisation for all leave before making any financial commitments. If the dates requested will affect the smooth running of the department, then requested dates may be refused.

▪ Reasonable notice should be given, even for casual days, in order to facilitate the smooth running of the department.

▪ You should endeavor to take all annual leave during the course of the calendar year. If necessary (manager approval required), a Max of 5 days can be carried forward into the following year and must be taken by the Easter Bank Holiday weekend. Unused holidays (in excess of five days), or annual leave carried forward and not taken by the Easter Bank Holiday weekend, will be lost. There is no provision for payment of unused holidays.

The firm reserves the right not to continue to accrue entitlement to paid holiday during any period of absence due to sickness, injury or other absence.

On the termination of your employment, your holiday entitlement for that calendar year is pro-rated for the number of complete calendar months worked in that year.

If, on the termination of your employment, you have taken more or less than your current year’s holiday entitlement, an adjustment based on your normal rate of pay will be made in your final payment, either by deduction or additional payment. The Company reserves the right to request that some/all of any outstanding, accrued holiday balance be taken during your notice period.