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CODE OF CONDUCT AND COMPLIANCE RULES
1. CBRE HOUSE RULES*
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 Compliance Director via the Personal Compliance Declaration Form which can be found under Quick Links via the Compliance & Best Practice intranet page https://intranet.cbre.com/Sites/EMEA-UnitedKingdom-EthicsandCompliance/en-GB.
No new such appointments may be accepted without the prior written approval of the UK Managing Director. Any additional employment outside the Company, e.g. working in a pub/restaurant at weekends, may be permissible but needs approval from HR. 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.
Personal Property Ownership and Co-Investment
Upon joining the Company, you must register details of any commercial investment property owned by you or your immediate family (spouse, children and beneficial trusts) via the Personal Compliance Declaration Form which can be found under Quick Links via the Compliance & Best Practice intranet page https://intranet.cbre.com/Sites/EMEA-UnitedKingdom-EthicsandCompliance/en-GB. You will be asked to confirm the validity of such information held once a year.
Ownership through inheritance whilst working for the Company must similarly be registered as above. Any proposed purchase of commercial or mixed use investment property, or any interest in such, must be approved by the Compliance Director prior to agreeing terms.
For the avoidance of doubt, the rules above do not apply to any residential property occupied by you or any members of your immediate family.
You may not commit the Company, whether in lieu of or in addition to fees payable, to co-invest with a client since this is against Company policy.
The Company reserves the right to discipline any employee who fails to declare such interests.
Stocks and Shares
You must seek prior approval from the Compliance Director (which may well be refused) before you buy or sell shares in any property related company where the Company is involved in instructions from a client which could be deemed as representing price-sensitive information. Once the instruction is completed and the information is in the public domain, you may apply to deal. Please refer to section 2 regarding Legal Sanctions.
Without the Compliance Director’s prior approval (which will generally be given) you may not buy or sell shares in any company, limited partnership or other collective investment scheme whose primary purpose is to invest in or develop property.
For the avoidance of doubt, you are free to deal in the shares of any entity not covered by the prior two paragraphs above.
On joining and whilst employed by the Company you must register ownership of the following, using the Personal Compliance Declaration Form which can be found under Quick Links via the Compliance & Best Practice intranet page https://intranet.cbre.com/Sites/EMEA-UnitedKingdom-EthicsandCompliance/en-GB.
shares in any private property companies (whether private or quoted)
a greater than 3% shareholding in any public company (property related or otherwise)
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.
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 Compliance Director at an early stage.
Failure to comply with the house rules above may result in disciplinary action.
2. RULES WITH LEGAL SANCTIONS*
CBRE Price Sensitive Information/ Market Abuse
As a firm authorised and regulated by the Financial Services Authority (FSA), CBRE Limited is bound by the FSA’s rules relating to Market Abuse and under the Criminal Justice Act 1993 Provisions for Insider dealing.
Market Abuse is the misuse of information and is defined in the Financial Services & Markets Act 2000 as “behaviour which is based on information which is not generally available to those using the market but which, if available to a regular user of the market, would or would be likely to be regarded by him as relevant when deciding the terms on which transactions in investments of the kind in question should be effected”.
The rules state that market users rely on the timely dissemination of such relevant information as they may reasonably expect to receive. Those who possess relevant information ahead of general dissemination should, therefore, refrain from basing their behaviour on that information until it is disseminated. Failure to do so would be considered Market Abuse and is punishable by the FSA by way of an unlimited fine and/or imprisonment. Under the Criminal Justice Act 1993 you could be imprisoned for up to seven years.
Potential instructions to advise on/value for take-over bids, flotations and mergers must be registered with the Compliance Director before they are accepted. He/she may, at their discretion, notify (or require you to notify) particular overseas offices to check for any potential conflict of interest and/or to ensure that no inappropriate share dealing occurs elsewhere in CBRE.
Upon confirmation of instructions you must advise the Compliance Director in writing of those members of staff “in the know” - and keep them informed of any changes.
The Company reserves the right to discipline any employee failing to observe the above or subsequently breaching confidentiality, whether or not such acts or omissions lead to legal action being taken against the Company or employees.
FCA Regulated Business
It is illegal for any Company employee who is not regulated by the Financial Conduct Authority (FCA) to undertake investment or insurance regulated activity without the prior approval of the Company and the FSA. If you are in any doubt as to whether you are regulated, contact the Compliance Director.
3. STANDARDS OF BUSINESS CONDUCT AND BUSINESS MANAGEMENT SYSTEM*
You must at all times conduct yourself in accordance with the Company’s Standards of Business Conduct (UK version). The full manual is available on the intranet.
At CBRE we pride ourselves on our strong ethical code. Respect, Integrity, Service and Excellence (RISE) are all important values in business and are essential to the continuing success of our company. We require everyone who represents CBRE to read, understand and adhere to our Standards of Business Conduct. Each of us is personally responsible for maintaining the highest standards of business conduct to ensure we continue to differentiate ourselves as the Company that global clients trust with their real estate strategies
You must at all times ensure that instructions on behalf of your clients are undertaken in accordance with the procedures laid down in the Business Management System and that you comply with its auditing requirements.
4. YOU MUST AT ALL TIMES ENSURE THAT YOU ARE IN COMPLIANCE WITH COMPANY POLICIES & PROCEDURES*
During your induction you will receive and/or be given access to a number of Company policies, procedures and training for compliance purposes. You will be asked to review them on the HR “Onboarding” page and “submit” that you have read and will comply with them. The company will rely on this as evidence that you have received, understand and will comply with the relevant policies and procedures.
