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Code of conduct and compliance rules
CBRE Investment Management house rules
Introduction
The CBRE Investment Management Compliance Policies & Procedures (the “CPP”), the Operating Policies & Procedures (the “OPP”), the CBRE Standards of Business Conduct, the UK Direct Policies and Procedures Manual (where it deviates from the OPP) together with the compliance manuals of our Financial Conduct Authority regulated businesses in the United Kingdom, set forth the policies, procedures and compliance requirements governing, how we run our business. You must ensure, as an employee, that your actions are compliant with the above-mentioned policies and procedures.
Outside interests & employment
CBRE Investment Management has a duty to manage and avoid conflicts of interests that may interfere with the interests of its clients. CBRE Investment Management relies on the integrity and undivided loyalty of our employees to maintain the highest level of objectivity in performing their duties. You have a duty of honesty and loyalty to CBRE Investment Management, to further its aims and goals and to work on behalf of its best interests with the highest level of integrity. You are expected to avoid situations in which your personal interest’s conflict, or have the appearance of conflicting, with those of CBRE Investment Management and to disclose those conflicts to the Company when they arise or might arise.
During your employment with CBRE Investment Management, you should obtain the prior written permission of your line management and the Compliance Department in relation to:
– External directorships
– Commercial property interests including a buy-let portfolio
– Material financial ownership interests in a supplier, competitor, or client of CBRE Investment Management. A material financial ownership interest is defined as more than 5% ownership interest.
Existing directorships in relation to the above should be notified to your line management and the compliance department. New appointments may not be accepted without the prior written approval of your line management and Compliance.
Personal account dealing
Both CBRE Investment Management Indirect and the UK Direct Business have policies in place in relation to personal account dealing. Please see the Company Intranet page or the UK compliance department, should you require a copy of the policy.
Gifts & Hospitality
General
Other than occasional small holiday gifts, meals, and non-lavish transportation (e.g. taxis), employees should not directly or indirectly offer or give gifts, favours, or other things of value to an existing or potential client that could be viewed as overly generous or aimed at influencing decision-making or making a person feel beholden to CBRE Investment Management or the employee.
Gifts
Without the Compliance Department’s and the head of the applicable business unit's written pre-approval, no employee may give or receive gifts having a fair market value in excess of (i) USD 100 (or the equivalent in local currency) per gift to or from any employee, consultant, investment committee or board member of an existing or potential client, investor, or vendor.
Entertainment
“Entertainment” includes meals, social events, hospitality events, charitable events, sporting events, leisure activity or events of like nature or purpose. Without the Compliance Department’s and the head of the applicable business unit's written preapproval, no employee may offer or receive entertainment having a fair market value in excess of (i) USD 250 (or the equivalent in local currency) per event per employee, consultant, investment committee or board member of an existing or potential client, investor, or vendor.
Regulatory obligations
It is a breach of the rules of our regulator, the Financial Conduct Authority, for an employee to undertake indirect investment regulated activity without the individual being certified as “fit and proper”. If you are in doubt as to whether you are a Senior Manager (statutory board director of the regulated entity) or Certified Staff, please contact the Head of UK Compliance.
For any new joiner coming into a Certified role or going on to the board of directors of the regulated entity, will be subject to a fit & proper assessment prior to being able to carry out their role. For existing Certified Staff or Senior Managers, they will be subject to an annual fit & proper assessment. If a Certified employee is not deemed to be fit & proper, subsequent meetings will take place between the employee, their line manager, senior management, People department, legal and compliance. If a Senior Manager is not deemed to be fit & proper, subsequent meetings will take place between the senior manager, the CEO, People department, legal and compliance.
It is a breach of the rules of our regulator under the Senior Manager and Certification Regime (SMCR), if an employee, subject to the conduct rules, fails to comply with these rules. See disciplinary procedures for further information.
It is also a breach of the rules of our regulator, and of the law, if an employee fails to report a suspicion of money laundering to the Head of UK Compliance, or fails to undertake know your client anti-money laundering checks on a client or counterparty, before entering into a transaction on the Company’s behalf.
Under the UK Bribery Act 2010, employees are prohibited from giving or receiving bribes and making facilitation payments.
Compliance with company policies and procedures
All new employees will receive compliance induction training shortly after joining the company. Employees will also be provided with copies of the Compliance Policies & Procedures (CPP) and the Operating Policies & Procedures (OPP), the CBRE Standards of Business Conduct and, where applicable, the compliance manual with respect to regulated business.
Compliance policies and procedures are available on the compliance section of the company’s intranet.
At least annually, employees will be required to attest that they have read understood and complied with all applicable compliance policies and procedures.
A failure to abide by the various in-house policies and procedures (including compliance policies) may result in disciplinary action, up to and including termination of employment.
Compensation & benefits Salary
Your salary is paid, in arrears, on the 24th of each month by credit transfer. If the 24th falls on a weekend you will be paid on the preceding Friday. Payslips can be accessed via myHR electronically. When you leave the company, the last payslip will be accessible externally via the ePay link.
If you change your bank account, please do so via myHR, Employee Self-service. The People Services team will be notified and approve.
If you have a query regarding your salary, please speak to your People team contact.
Salaries are reviewed annually on 1 April, 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 employee’s volition, are not entitled to a salary review.
Income tax
Except for PAYE deductions made by the Company from your salary, it is your responsibility to deal directly with the HM Customs & Revenue regarding your tax affairs, including taxable benefits such as cars and private health cover.
The address of the Company’s Tax Office for all CBRE IM staff is:
HM Revenue & Customs Pay As You Earn PO Box 1970
Liverpool
L75 1WX
Telephone: 0845 3000 0627
CBRE Investment Management Company Reference: 951/A18075
Incentive pay schemes
You will be eligible for incentive pay consideration in accordance with the relevant scheme rules in operation at the time of your employment.
This will be paid, where applicable, with March salaries to all staff employed on 31 March and who have joined the Company before 30 September in the previous year. Employees on any form of notice, be it of the Company’s or employee’s volition, are not entitled to incentive payments. Pro rata payments may be made to staff joining or retiring during that year.
Company cars
1. The Company normally provides cars or, alternatively, a cash allowance to qualified and/or professional staff and, at discretion, to other staff in accordance with the Company’s car policy. Car and cash allowance levels relate to seniority and are reviewed on a regular basis.
2. The Company reserves the right to, and will consider the commercial viability of, reallocating any existing vehicle from the car fleet before it considers acquiring a new vehicle. All employees will keep the vehicle until the existing contract expires, at which time the employee will have the option of another Company car or the cash allowance. New car contracts are for a period of four years which must be held onto for the full duration unless you leave. The range of cars available is determined by a monthly cost limit and depends on your level, but cars which are not appropriate for business use, such as two-seater sports cars, need the approval of your Departmental Director. MPVs are not allowed under the scheme.
3. Business mileage may be claimed back in line with the HM Customs & Revenue rates which are published on the Finance section of the intranet.
4. Details of the Company’s car policy and procedures can be obtained from the People team and the Intranet. The handbook of the leasing Company, Zenith, which must be carried in the car at all times, covers items on maintenance, repair and use which it is the individual’s responsibility to strictly adhere to. All queries should be directed to Zenith in the first instance. Their telephone number is 0113 348 8686.
5. Those who opt for the cash allowance in lieu of a Company car can, if they wish, source, and finance a private car by using the ‘personal lease scheme’ arranged by Zenith for CBRE employees. Further details are available on the Company’s Intranet. If you opt for the cash alternative and you use your own vehicle for Company business, you must ensure that your private car is fully insured for such Company use.
6. Where private cars are used for approved business purposes, a mileage charge will be reimbursed through the normal expense procedure. There are two rates, and you need to ensure that you claim the correct rate. One relates to those who are taking the cash allowance in place of a Company car. The other relates to those who have no entitlement to a Company car. The current rates are available from Finance or the intranet.
7. When using your private car for business, it is your responsibility to ensure that you are fully insured for business use under your own insurance policy, as the Company’s policy does not cover you.
8. The Company’s cars are insured to be driven by the Company’s employees, their spouse/partner, and dependants (with some restrictions, details of which are available from the People Benefits Administrator). If anyone wishes their car to be driven by someone other than themselves or their family, they should obtain the explicit agreement of the Head of Department in writing beforehand. When seeking consent, you should produce the driving licence of the additional driver (or a photocopy of it).
9. The Company’s car insurance for the family is for social, domestic and pleasure purposes only. The family are not insured to carry out another Company’s or their own business in the vehicle, with the exception of commuting to and from their normal place of work. Normal place of work is defined as their normal work premises and should be interpreted as wherever they carry out their business.
10. Where there is a charge on the Company’s insurance policy (e.g. accidents, theft, and miscellaneous damage) the employee will pay the first £150 of the £250 excess. If the driver/custodian at the time of the claim arising is not the employee to whom the car is allocated (or their spouse) then the full £250 will be paid by the employee.
11. In incidents where a Company car is subject to criminal damage while on Company business which is reported to the police and a crime number allocated, then no insurance excess of £150 will be charged to the driver. Full details are available in the Company’s car policy.
12. In the event of damage etc. being below £250 and no claim being made on a third party’s insurance and the Company has to meet the full cost of the damage, the employee to whom the car is allocated will pay the first £150.
13. The Company’s car insurance policy does not provide cover for the loss of your personal possessions. It is your responsibility to insure your personal possessions.
14. If you receive any endorsements or are suspended it is necessary, for insurance purposes, to inform the People department at the time of the incident. Failure to declare endorsements or suspension is a formal disciplinary matter and the insurance cover will be void. Full details are available in the Company’s car policy.
15. If you are leaving the Company, the following courses of action are open to you, subject to the Company’s agreement:
You may be able to purchase your vehicle from Zenith. If, however, the current contract has not expired, a termination fee will be imposed by Zenith and you will be required to pay any excess mileage costs as well.
The current contract may be transferred to your new employer provided all arrangements are made prior to you leaving the Company and that Zenith have given their approval. Any excess mileage costs will be borne either by the new employer or by you. This option is ONLY available if the Company does not incur a loss as a result of transferring the contract. If you wish to pursue this you should contact Zenith, and they will make the necessary arrangements between Zenith and your new employer.
– The car may be returned to CBRE. The car should be cleaned both inside and out and any repairs completed before returning the vehicle. A deduction of £250 will be made from your salary. Any refurbishment work necessary to the vehicle will be deducted from the £250. If no work is necessary, the full £250 will be returned to you as soon as possible. Please inform Zenith of any outstanding insurance claims and ensure that you have completed the necessary claim forms.
– Personal charges will be made for all damage other than reasonable fair wear and tear, e.g. stone chips (4.15.3 in the full policy).
16. When an employee returns a Company car at the end of its lease period or when it is being transferred to another employee they will have £250 deducted from their pay to cover any charges for all necessary work, other than fair wear and tear, that may be necessary to make the vehicle ready for auction or transfer, e.g. panel replacements, panel repairs, re-sprays (other than stone chips), broken wing mirrors, lights, bumpers, tyres etc. Any refurbishment work necessary to the vehicle will be deducted from the £250. If no work is necessary, the full £250 will be returned to you as soon as possible. Please ensure that the car has a MOT certificate, if necessary, and that it is returned in a clean state.
17. Where employees have excess lease payments, these apply for the full period of the lease. Therefore, if someone leaves the Company or transfers the car to another employee before the lease expires, it is the responsibility of the original employee to pay for the outstanding balance of the excess payment and this will be deducted from their salary.
18. It is the responsibility of the employee to pay parking fine tickets and congestion charge fines (see car manual for further details). However, anyone who incurs a congestion charge whilst using their car on Company business should claim reimbursement through the normal expenses system, as with car parking/toll charges.
Pension Pension scheme
As of 1 May 2010, the Company operates a Group Self Invested Pension Scheme.
It is a ‘salary sacrifice’ scheme, managed by Legal and General. Employee minimum contributions are 5% of salary. Employer contributions are as follows:
If you elect not to join the contributory pension scheme, you will be auto enrolled in a pension scheme in line with statutory requirements and legislated contributions following three months of employment. You have the right at this time to opt out of the auto enrolment scheme. Full details of the scheme are available from the Benefits Adviser. The rules and provisions of such a scheme may be subject to change from time to time.
The rules and provisions of the pension scheme may be subject to change from time to time. For further details on this or if you have any queries on other closed pension schemes please contact the Benefits Team within the People Department.
Auto enrolment scheme
If you do not join the Company’s pension scheme you will be automatically enrolled into the Government scheme following three months of employment. Employee contribution is 5% and Employer contribution is 3% also. If you do not want to be part of the auto enrolment scheme, in the month of your first deduction you will receive a pack from Legal & General and this will include details on how to opt out.
Life insurance
The Company provides free life insurance to all staff which covers your life for a sum equal to three times annual basic salary, subject to the provisions of the Company employee pension scheme. This will increase to four times the annual basic salary for employees who actively join the contributory salary sacrifice pension scheme. This increase will not take effect if you are auto enrolled into a pension scheme.
Permanent health insurance
The Company provides Permanent Health Insurance (PHI) for those at Associate level and above.
PHI is a form of income replacement for long term sickness. After six months’ total disability whilst in the Company’s employment, and subject to insurance company approval, you will be reimbursed 75% of your basic salary (up to a maximum of £120,000 per annum, including employer pension contributions), less benefits. All other benefits except from life assurance and private health insurance, where applicable cease on commencement of PHI. This policy is in place until the age of 65.
Private medical insurance
The Company provides private health benefits to all staff (and their spouses and dependent children under the age of 21 or 25 if in full-time education) who wish to join the scheme, subject to the provisions of the scheme. We are insured with AXA PPP Corporate Health Plan level 2 with pre-existing conditions covered. This is a taxable benefit. Details of the tax liability are available with the joining forms in your benefits pack, or via the Benefits Team. Please contact the Benefits team to add additional family members to the scheme.
Medical screening
The Company provides medical screening for all employees at Associate level and above upon reaching the age of 40. The screenings then take place every two years after that. If you are currently eligible or when you become eligible, our provider will write to you inviting you to schedule an appointment. Please contact the People department if you have any queries.
Notification of changes in information
It is the employees’ responsibility to notify the People team, via the PeopleSoft system, of any changes that affect employee records, i.e. changes in name, address, telephone number, marital status, number of dependants, next of kin and bank details.
Holidays Holiday entitlement
The holiday year is 1 January to 31 December and holiday entitlement is 25 days (30 for Directors and above) for all full-time staff. However, in the calendar year of joining, you shall be entitled to holiday on the following scale:
Where the joining date is between day 1 and 15 of the month, employees are entitled to the full allowance for that month. Where the joining date is day 16 or later, employees are entitled to one day for that month.
In addition you are entitled to Public Holidays plus 2 extra days nominated by the Company in the Christmas/New Year period. During all holidays you are entitled to normal rate of remuneration.
If you work part-time, your holiday entitlement is varied pro rata in line with your agreed working arrangements and is dependent upon the number of days you work each week.
All holiday dates are subject to the prior approval of your line manager. You must obtain authorisation for all leave before making any financial commitments. No more than three weeks can be taken consecutively.
You should endeavour to take all annual leave during the course of the year. If necessary, up to five days may be carried forward into the following year and must be taken by the 30 April. Days in excess of five, or annual leave carried forward and not taken by the 30 April, will be lost. There is no payment in lieu for unused holiday except on termination of employment for the current calendar year.
Holiday entitlement in the calendar year your employment terminates is pro rata to the number of completed calendar months worked in that year, on the following basis:
Holiday Entitlement
Where the leaving date is between day 1 and 15 of the month, employees are entitled to one day for that month. Where the leaving date is day 16 or later, employees are entitled to the full allowance for that month.
If, on the termination of your employment, you have taken more or less than your current year’s holiday entitlement as calculated above, an adjustment based on your normal rate of pay will be made in your final payment, either by way of deduction if you have taken more than your entitlement or by way of an additional payment where you have taken less than your current year’s entitlement. The Company reserves the right to request that some or all of any outstanding, accrued holiday balance be taken during your notice period.
Holiday purchase scheme
The company allows employees to purchase up to five days additional holiday per year with payroll deductions taken over 11 months.
For more details please contact the Benefits team.
Additional leave
Jury service
If you are required to attend jury service, you should immediately inform your Line Manager and the People department. There is no Loss of Earnings involved as you will continue to be paid in the normal way by the Company. Therefore, you do not need to have any paperwork completed by the People department. On completion of your jury service you should let the People department have the dates for record purposes. It is your responsibility to claim from the courts any amounts relating to travelling and subsistence as these will not be reimbursed by the Company.
Should the court release you from jury duty earlier than scheduled or not require your attendance at all, you are expected to immediately inform your Line Manager and return to work that same day, or as soon as it is practicably possible.
If deemed necessary, the Company reserves the right to ask if any employee’s attendance may be deferred for operational reasons.
Parental leave/time off for dependants
For further details, please refer to the Family Policies later on in this handbook.
Reserve Armed Forces
CBRE IM values the transferable skills gained by staff who are members of the Reserve Forces.
Those who are members of the Volunteer Reserve Forces Volunteer Reserve Forces the Royal Naval Reserve (RNR), the Royal Marines Reserve (RMR), the Army Reserve (AR), and the Royal Air Force Reserves (RAuxAF) are allowed 10 days additional paid leave (pro rata for part time employees) for attendance at their two-week annual camp or equivalent continuous training exercises. Reservists are to ensure their team head receives at the beginning of their training year advance notification of the key training events that the employee is expected to attend.
Adult Cadet Force Instructors completing their annual training requirement of 21 days will be allowed 5 days additional paid leave (pro rata for part time employees).
Attendance is to be evidenced by a letter signed by their Commanding Officer or PSAO. Any additional period should be taken from annual leave.
Charity/volunteering work
Where an employee is involved in a charity or volunteering event, up to two additional days leave per year may be granted. Please see full volunteering policy on the intranet.
Bereavement leave
You are entitled to up to 4 weeks paid bereavement leave with agreement from your line manager and People Advisor or Business Partner.
Moving house
The Company allows up to one additional day per year for the purposes of moving home. This must be agreed in advance with your manager.
Marriage/Civil partnership
You are allowed one additional day’s leave for your special occasion. This extra day must be agreed in advance with your manager. You will also receive a gift from the Company. The gift is brought to you by From Babies with Love and their affiliated partners who provide unique gifts and donate 100% of their profit to orphaned and abandoned children around the world. Please inform the People team of your marriage/civil partnership date in advance.
Long service awards
The Company recognises and wishes to acknowledge the loyalty and commitment evidenced by long service. Awards are granted as follows:
All employees are eligible, including ex-Equity Partners. If you work part-time, your holiday entitlement is varied pro rata in line with your agreed working arrangements and is dependent upon the number of days you work each week.
In any event you will not be entitled to receive payment if you are no longer employed or have given, or received, notice of termination of employment.
Benefits for part time staff
Benefits (i.e. holidays, life insurance, PHI, car/cash allowance in lieu, pension contributions etc.) are allocated on a pro rata basis to reflect part time hours. This will apply to all new part time employees and those who move to part time for whatever reason.
Those who were part time before 1 April 2005 will continue on their personal basis until their contracted hours change, at which time benefits going forward will be on a pro rata basis.
Employee assistance programme
As an employee of CBRE Investment Management you and your family have access to an Employee Assistance Programme in association with Aviva.
The service is totally confidential and anonymous, available 24 hours a day, 365 days a year and provides access to specialist nurses and legal advisers.
Simply call the following telephone number and quote your name, employer and department: 0800 404 9452
Season ticket loans
Interest free loans for season tickets (rail, Oyster and bus) are available for permanent employees on a discretionary basis to a maximum loan of £10,000. Fixed Term Contract employees with a contract length over 12 months are also eligible for this benefit. You can purchase an annual season ticket repayable over 12 months. Before you sign up for a season ticket with Abellio, please ensure you are fully aware of the terms & conditions attached to taking out a Season Ticket Loan.
You can apply either through the myBenefits portal. Employees will receive an email notification on or around the 1st of the month following their joining date to access myBenefits portal and they will be able to select the season ticket loan as a benefit. Or they apply directly through Abellio’s website https://www.abellioseasontickets.com/tickets/cbre-investment-mana
On leaving the Company, any outstanding loan amount will be deducted in payroll; this must be repaid in full before you leave. Should you wish to seek a refund for the outstanding value of the ticket, please let the People Services Shared Centre know. Under the rules of our engagement with the external provider, any refund will be made directly to the Company and repaid to you via BACS once the funds have been received from them.
Student loans
An interest free loan of £1,200 is available to those employees who have completed fulltime education within the 12 months immediately prior to joining. This must be applied for, via the People department, within six months of joining the Company.
On leaving the Company, any outstanding amount must be repaid in full before you leave. Any refund, whether you are leaving the Company or moving closer to work, must be by paid via payroll or by BACS directly to the Company.
Internal vacancies
Vacancies are advertised internally on the intranet. If you would like to apply for a position, please apply to the People department in the first instance. Please refer to the transfer policy available on the intranet.
Recruitment bonus (refer a friend)
A taxable bonus of up to £5,000 may be paid to staff for the introduction of permanent employees (excluding transfers from CBRE Group, either within the UK or overseas) within the London CBRE Investment Management Company. This bonus is as follows:
– £1,000 for Support staff and part-qualified Surveyors (excl. Graduate Programme)
– £2,500 for Fee Earners up to Senior Analyst
– £3,500 for Associate or Senior Associate level
– £5,000 for Director level or above
The Company reserves the right to amend these rates at any time, and any award payable will be based on the rates applicable at the date the new employee joins.
This bonus will normally be paid on completion of six months’ service by the new person, provided that the introducer is still with the Company at that stage and not serving any period of notice. Payment is via the payroll and, depending on dates, may be made with the following month’s salary.
Team award
An award may be claimed by a team if the introduction has been a collective effort. In this case the award may be used for a team event and a nominated individual, approved by the appropriate Department head, will receive the award through the payroll to be spent on the team.
Joint award
An award may be claimed by two or three team members who will each receive equal shares.
Please note
The claim for the bonus must be made within one month of the new employee joining the Company by an email of approval from your Head of Department being sent to the People department.
All employees and Directors will be eligible except for Managing Directors and Heads of Departments.
It is not payable in respect of the intake of graduates on to the Graduate Training Programme. Nor is it payable for employees transferring within the CBRE Limited business.
This applies to the UK only.
The bonus is payable at the discretion of the People Director, whose decision will be final, taking into account the particular circumstances.
Sports and social
CBRE has a diverse range of sports clubs which employees of CBRE Investment Management are encouraged to join. The following sports currently have their own club: Cricket, Football, Golf, Hockey, Netball, Running, Softball, Squash and Tennis.
These clubs participate in tournaments and privately arranged matches with other surveying firms, institutions, and clients. Details can be obtained from the club captains or the Sports & Social Committee.
Sports club events (as distinct from client entertainment on sporting occasions) which take place during business hours are to be taken as holiday by the staff involved. If it is necessary to hold an event during business hours, it should take up no more than half a day.
CBRE Investment Management also have a social committee which organises a number of activities throughout the year.
