CBRE Investment Management Employee Handbook June 2023

Employee Handbook

NB: The Employee Handbook is updated on a regular basis. A copy is held on the Company’s Intranet site. It is your responsibility to check this from time to time.

UPDATED June 2023

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.

Learning & development

Training, career development & promotion

The Company ensures that opportunities for training, career development and promotion are made equally available to all employees.

The Company is keen to promote a working environment which encourages the individual development of its people. A copy of our training policy is available on the CBRE IM intranet.

Training needs are identified by you and your Manager, through the appraisal system, succession planning and, where appropriate, career planning meetings.

Appraisals

Appraisals for all staff take place annually around January/February in addition to any informal performance reviews within your team throughout the year.

Together with your Line Manager, you will review your performance against the criteria set out in the Career Framework (available from the intranet) for your level/role, and it is an opportunity to identify and set out any performance, learning and development objectives for the year ahead.

Continuing Professional Development (CPD)

All professional staff are required to complete and keep a record of the Continuing Professional Development that they have undertaken in compliance with the relevant professional body. Random audits may be carried out each year by the professional body.

Promotion

Promotions are generally considered once a year in January and are effective 01 April, for all levels. Details regarding nomination and paper submission are available from your line manager.

Policies & procedures

Equal opportunities

Introduction

CBRE is committed to supporting the principle of equal opportunities and opposes all forms of unlawful or unfair discrimination on the grounds of colour, race, nationality, ethnic origin, sex, pregnancy, marital or civil partnership status, disability, religion, belief, age, sexual orientation, gender-assignment, trade union membership or on the fact that an individual is a part -time worker or fixed term employee.

Our aim is to recruit, train and promote the best person for the job and to create a working environment free from unlawful discrimination, victimisation, and harassment in which all employees are treated with dignity and respect. All job applicants, employees and others who work for us will be treated fairly and will not be discriminated against on any of the above grounds.

All employees will be made aware of the requirements of this policy and will be obliged to co-operate to ensure that the policy is carried out effectively.

Any form of discrimination may be unlawful and will be treated as a disciplinary offence resulting, if appropriate, in disciplinary action. Note that the Equal Opportunities Policy, including the harassment and victimisation policy and complaints procedure, do not form part of employees’ contracts of employment and may be changed by CBRE in its absolute discretion at any time.

1. Scope of Equal Opportunities Policy

This policy applies to the advertisement of jobs, recruitment, terms and conditions of employment, career development, counselling, training, promotion, grievance and disciplinary procedures and all other aspects of employment.

All employees are required to comply with the Equal Opportunities Policy when dealing with other employees (including temporary or agency staff and consultants), job applicants, clients, suppliers, customers and contacts of the Company, and anyone else with whom they come into contact during the course of their employment.

In particular, all employees must take care to guard against more subtle and unconscious forms of discrimination which may not be immediately obvious. This may result from generalisations about the capabilities, characteristics or interests of a particular group which influence the treatment of individuals.

2. Who is responsible for this policy?

Our board of directors (the board) has overall responsibility for the effective operation of this policy and for ensuring compliance with discrimination law. Day-to-day operational responsibility, including regular review of this policy, has been delegated to the Equal Opportunities Officer.

All managers must set an appropriate standard of behaviour, lead by example and ensure that those they manage adhere to the policy and promote our aims and objectives with regard to equal opportunities. Managers will be given appropriate training on equal opportunities awareness and equal opportunities recruitment and selection best practice. The People Director has overall responsibility for equal opportunities training.

If you are involved in management or recruitment, or if you have any questions about the content or application of this policy, you should contact the Equal Opportunities Officer to request training or further information.

3. Recruitment

CBRE will ensure that information about vacancies will be circulated as widely as possible in the circumstances to ensure that it reaches all sections of the community regardless of colour, race, nationality, ethnic origin, sex, pregnancy, marital or civil partnership status, disability, religion, belief, age, sexual orientation, genderassignment, trade union membership or on the fact that an individual is a part -time worker or fixed term employee. All applications will be welcomed and will be considered on the relative merits of the applicant against the job and/or person specification for the position.

Job and person specifications will only include criteria which are objectively required for the duties and responsibilities of the vacancy.

If there is a genuine and lawful reason for limiting the vacancy to a particular group, this will be clearly stated, and the grounds for it, on any advertisements.

Applicants should not be asked about health or disability before a job offer is made. There are limited exceptions which should only be used with the People department approval. For example:

Questions necessary to establish if an applicant can perform an intrinsic part of the job (subject to any reasonable adjustments).

Questions to establish if an applicant is fit to attend an assessment or any reasonable adjustments that may be needed at interview or assessment.

To monitor diversity in the range of applicants (which will not form part of the decision-making process); and

To take positive action to assist disabled applicants.

CBRE is required by law to ensure that all employees are entitled to work in the UK. Assumptions about immigration status should not be made. All prospective employees, regardless of nationality, must be able to produce original documents before employment starts to satisfy immigration legislation. A list of acceptable documents is available from the People team.

4. Terms and Conditions of Employment

CBRE will offer terms and conditions of employment that are free from all forms of direct and indirect discrimination and apply equally regardless of colour, race,

nationality, ethnic origin, sex, pregnancy, marital or civil partnership status, disability, religion, belief, age, sexual orientation, gender-assignment, trade union membership or on the fact that an individual is a part -time worker or fixed term employee. No requirements or conditions will be imposed, directly or indirectly, which will or might place any group of employees at an unfair or unlawful disadvantage.

Grievance and disciplinary procedures will be operated without discrimination on the grounds of colour, race, nationality, ethnic origin, sex, marital or civil partnership status, disability, religion, belief, age, sexual orientation, gender-assignment, trade union membership or on the fact that an individual is a part -time worker or fixed term employee or any other unlawful grounds.

5. Training, Career Development and Promotion

The Company will ensure that opportunities for training, career development and promotion are made equally available to all employees. The principal method of identifying training needs will be through the appraisal procedures and promotion decisions will be based on merit alone.

6. Disability Code of Good Practice

CBRE values the individual contribution of all employees and prospective employees from all sectors of the community at large. CBRE recognises its social, moral and statutory duty to employ people with disabilities and will do all that is practicable to meet this responsibility. The Company operates, therefore, the following Code of Good Practice on Disability:

CBRE will take steps to raise awareness of disability throughout the organisation, particularly targeting all staff involved in recruitment and selection processes.

CBRE will take reasonable steps to ensure that the working environment, working practices and terms and conditions of employment do not prevent disabled people from taking up positions for which they are suitably qualified and, in all other respects, the best person for the job.

CBRE will bear in mind the desirability of avoiding barriers to the employment of disabled people when acquiring and fitting out buildings with equipment and devising working practices.

CBRE will take steps to ensure that all disabled people have the same opportunities, subject to reasonable cost limitations/practicalities, as other staff to develop their full potential within the organisation.

Only a person of the level of the People Director or equivalent will take any decision not to make an adjustment which might enable or assist an employee or a prospective employee to be employed in a particular post. Before making such a decision, the relevant person will ensure that all possible adjustments have been fully investigated, including consultation with the employee or prospective employee concerned and any appropriate expert advice.

7.

Any employee who becomes disabled whilst in employment will be given the full support of managers and CBRE's People Department to maintain, or return to, a job appropriate to his/her experience and abilities.

CBRE will encourage the participation of disabled employees to ensure that, wherever possible, its employment practices recognise and meet their needs and will consult disabled employees on action to make sure they develop and use their abilities at work.

CBRE will continue to provide services and facilities to clients with disabilities.

Further guidance can be obtained on an entirely confidential basis from the People Department. If you know or believe you might be disabled, you are warmly encouraged to discuss this with the People Department so that CBRE can ensure you achieve your full potential and that it complies with its duties.

Discrimination, Harassment and Victimisation in the workplace

CBRE is committed to providing a workplace where everyone has the right to work in an environment which promotes equal opportunity and prohibits discriminatory practices. CBRE will not tolerate any form of discrimination, harassment, or victimisation by or against employees. It is the obligation of all employees to behave in a way that supports this policy.

This policy is not designated to discourage normal social relations among colleagues or with the public. Its aim is to prevent discrimination or harassment. It is the responsibility of each individual to be sensitive towards the impact that he/she has on others and not to discriminate against or harass colleagues or condone discrimination or harassment by others. The policy applies not only to working at CBRE's premises, and those of any third party, but also includes travelling or staying away from home whilst on business or for a reason related to your employment.

8. Equal Opportunities Officer

A senior employee of the Company is appointed Equal Opportunities Officer. The current Equal Opportunities Officer for the Company is the People Director.

The Equal Opportunities Officer will, with the assistance and co-operation of senior management, the People Department and other employees, take steps to ensure universal compliance with the policy.

9. Breaches of this policy

If you believe that you may have been discriminated against you are encouraged to raise the matter through our Grievance Procedure. If you believe that you may have been subject to harassment you are encouraged to raise the matter through our Antiharassment Policy. If you are uncertain which applies or need advice on how to proceed you should speak to the Equal Opportunities Officer.

Allegations regarding potential breaches of this policy will be treated in confidence and investigated in accordance with the relevant procedure. Staff who make such allegations in good faith will not be victimised or treated less favourably as a result.

False allegations which are found to have been made in bad faith will, however, be dealt with under our Disciplinary Procedure.

Any member of staff who is found to have committed an act of discrimination or harassment will be subject to disciplinary action. Such behaviour may constitute gross misconduct and, as such, may result in summary dismissal. We take a strict approach to serious breaches of this policy.

10. Monitoring

To ensure that this policy is operating effectively, and to identify groups that may be under-represented or disadvantaged within the Company, we may monitor employees and applicants' ethnic group, gender, disability, sexual orientation, religion and age. Provision of this information is voluntary and it will not adversely affect an individual's chances of recruitment or any decision related to their employment. Analysing this data helps the Company to take appropriate steps to avoid discrimination and improve equality and diversity.

Equal opportunities policy

CBRE is committed to supporting the principle of equal opportunities, and opposes all forms of unlawful or unfair discrimination on the grounds of colour, race, nationality, ethnic origin, sex, pregnancy, marital or civil partnership status, disability, religion, belief, age, sexual orientation, gender-assignment, trade union membership or on the fact that an individual is a part -time worker or fixed term employee.

Our aim is to recruit, train and promote the best person for the job and to create a working environment free from unlawful discrimination, victimisation and harassment in which all employees are treated with dignity and respect. All job applicants, employees and others who work for us will be treated fairly and will not be discriminated against on any of the above grounds.

All employees will be made aware of the requirements of this policy and will be obliged to co-operate to ensure that the policy is carried out effectively.

Any form of discrimination may be unlawful and will be treated as a disciplinary offence resulting, if appropriate, in disciplinary action. Note that the Equal Opportunities Policy, including the harassment and victimisation policy and complaints procedure, do not form part of employees’ contracts of employment and may be changed by CBRE in its absolute discretion at any time.

Scope of equal opportunities policy

This policy applies to the advertisement of jobs, recruitment, terms and conditions of employment, career development, counselling, training, promotion, grievance and disciplinary procedures and all other aspects of employment.

All employees are required to comply with the Equal Opportunities Policy when dealing with other employees (including temporary or agency staff and consultants), job applicants, clients, suppliers, customers and contacts of the Company, and anyone else with whom they come into contact during the course of their employment.

In particular, all employees must take care to guard against more subtle and unconscious forms of discrimination which may not be immediately obvious. This may result from generalisations about the capabilities, characteristics or interests of a particular group which influence the treatment of individuals.

Recruitment

The Company will ensure that information about vacancies will be circulated as widely as possible in the circumstances to ensure that it reaches all sections of the community regardless of colour, race, nationality, ethnic origin, sex, pregnancy, marital or civil partnership status, disability, religion, belief, age, sexual orientation, gender-assignment, trade union membership or on the fact that an individual is a part -time worker or fixed term employee. All applications will be welcomed and will be considered on the relative merits of the applicant against the job and/or person specification for the position.

Job and person specifications will only include criteria which are objectively required for the duties and responsibilities of the vacancy.

If there is a genuine and lawful reason for limiting the vacancy to a particular group, this will be clearly stated, and the grounds for it, on any advertisements.

Applicants should not be asked about health or disability before a job offer is made. There are limited exceptions which should only be used with the People team approval. For example:

– Questions necessary to establish if an applicant can perform an intrinsic part of the job (subject to any reasonable adjustments);

– Questions to establish if an applicant is fit to attend an assessment or any reasonable adjustments that may be needed at interview or assessment;

– To monitor diversity in the range of applicants; and

– To take positive action to assist disabled applicants.

The Company are required by law to ensure that all employees are entitled to work in the UK. Assumptions about immigration status should not be made. All prospective employees, regardless of nationality, must be able to produce original documents before employment starts to satisfy immigration legislation. A list of acceptable documents is available from the People team.

Terms and conditions of employment

The Company will offer terms and conditions of employment that are free from all forms of direct and indirect discrimination and apply equally regardless of colour, race, nationality, ethnic origin, sex, pregnancy, marital or civil partnership status, disability, religion, belief, age, sexual orientation, gender-assignment, trade union membership or on the fact that an individual is a part -time worker or fixed term employee. No requirements or conditions will be imposed, directly or indirectly, which will or might place any group of employees at an unfair or unlawful disadvantage.

Grievance and disciplinary procedures will be operated without discrimination on the grounds of colour, race, nationality, ethnic origin, sex, marital or civil partnership status,

disability, religion, belief, age, sexual orientation, gender-assignment, trade union membership or on the fact that an individual is a part -time worker or fixed term employee or any other unlawful grounds.

Training, career development and promotion

The Company will ensure that opportunities for training, career development and promotion are made equally available to all employees. The principal method of identifying training needs will be through the appraisal procedures and promotion decisions will be based on merit alone.

Disability code of good practice

The Company values the individual contribution of all employees and prospective employees from all sectors of the community at large. The Company recognises its social, moral and statutory duty to employ people with disabilities and will do all that is practicable to meet this responsibility. The Company operates, therefore, the following Code of Good Practice on Disability:

– The Company will take steps to raise awareness of disability throughout the organisation, particularly targeting all staff involved in recruitment and selection processes.

The Company will take reasonable steps to ensure that the working environment, working practices and terms and conditions of employment do not prevent disabled people from taking up positions for which they are suitably qualified and, in all other respects, the best person for the job.

– The Company will bear in mind the desirability of avoiding barriers to the employment of disabled people when acquiring and fitting out buildings with equipment and devising working practices.

– The Company will take steps to ensure that all disabled people have the same opportunities, subject to reasonable cost limitations/practicalities, as other staff to develop their full potential within the organisation.

– Only a person of the level of the People Director or equivalent will take any decision not to make an adjustment which might enable or assist an employee or a prospective employee to be employed in a particular post. Before making such a decision, the relevant person will ensure that all possible adjustments have been fully investigated, including consultation with the employee or prospective employee concerned and any appropriate expert advice.

Any employee who becomes disabled whilst in employment will be given the full support of managers and the Company’s People Department to maintain, or return to, a job appropriate to his/her experience and abilities.

– The Company will encourage the participation of disabled employees to ensure that, wherever possible, its employment practices recognise and meet their needs and will consult disabled employees on action to make sure they develop and use their abilities at work.

– The Company will continue to provide services and facilities to clients with disabilities.

Further guidance can be obtained on an entirely confidential basis from the People Department. If you know or believe you might be disabled, you are warmly encouraged to discuss this with the People Department so that the Company can ensure you achieve your full potential and that it complies with its duties.

Policy on discrimination, harassment and victimisation

This policy is applicable to all employees of the Company. It forms part of the Company’s general policy on equal opportunities.

The Company is committed to providing a workplace where everyone has the right to work in an environment which promotes equal opportunity and prohibits discriminatory practices. The Company will not tolerate any form of discrimination, harassment, or victimisation by or against employees. It is the obligation of all employees to behave in a way that supports this policy.

This policy is not designated to discourage normal social relations among colleagues or with the public. Its aim is to prevent discrimination or harassment. It is the responsibility of each individual to be sensitive towards the impact that he/she has on others and not to discriminate against or harass colleagues or condone discrimination or harassment by others. The policy applies not only to working at the Company’s premises, and those of any third party, but also includes travelling or staying away from home whilst on business or for a reason related to your employment.

Definition of discrimination, harassment and victimisation

Any behaviour under the following headings will not be tolerated. Disciplinary action, including dismissal for serious offences, will be taken against any person violating this policy.

The Equality Act 2010 is concerned with discrimination and harassment in respect of the following "Protected characteristics":

– Age

– Disability

Gender reassignment

– Marriage and civil partnership

– Pregnancy and maternity

– Race

– Religion or belief

– Sex

– Sexual orientation

Discrimination

Discrimination by or against an employee is prohibited unless there is a specific legal exemption. Discrimination may be direct or indirect and it may occur intentionally or unintentionally.

– Direct discrimination occurs where a person has been treated less favourably than another because of one or more of the protected characteristics.

– Indirect discrimination occurs where someone is disadvantaged by an unjustified provision, criterion or practice that also puts other people with the same characteristic at a particular disadvantage. Any such provision, criterion or practice will need to be objectively justified.

Harassment

Harassment is a form of discrimination and is any unwanted conduct (which includes verbal or physical abuse, advances or any other behaviour which has the purpose or effect of violating another person’s dignity or of creating an intimidating, hostile, degrading, humiliating or offensive environment) related to a relevant protected characteristic. The following types of behaviour may amount to harassment:

– physical assault;

– physical or verbal abuse;

– threats;

– suggestive comments or gestures;

– offensive gestures, language, gossip or jokes;

– insulting or abusive behaviour or comments;

– isolation or exclusion;

– bullying;

– persistent criticism or humiliation;

unfair allocation of work or responsibilities. This list gives examples only and is not exhaustive.

Sexual harassment

Sexual harassment is one form of harassment. Generally it involves conduct where a person persists in behaviour towards another and the person knows or ought reasonably to know that such behaviour is unwelcome to the other because it is perceived to be of a sexual nature and offensive. It is a form of sexual discrimination and as such is unlawful under the Sex Discrimination Act 1975.

The following types of behaviour may amount to sexual harassment:

– unwanted physical conduct, including unnecessary touching, patting, pinching or brushing against another employee’s body,

– verbal conduct of a sexual nature, for example making suggestive remarks or engaging in unwanted flirtation;

unwelcome sexual advances, continued suggestions of social activity outside work after it has been made clear that this is unwelcome;

– non-verbal conduct of a sexual nature; for example making sexually suggestive gestures

– the display of sexually suggestive or pornographic pictures, the sending of sexually harassing messages or images through electronic mail;

– sex-biased conduct;

– the telling of sexist jokes

– conduct that denigrates, ridicules, intimidates or is physically abusive towards an employee because of their sex, sexual orientation, marital or civil partnership status. This list gives examples only and is not exhaustive.

Sexual harassment by someone of the same sex as the victim is also covered by this policy.

Duties of supervisors

Where a supervisor (whether a manager or other person holding supervisory responsibilities) becomes aware of an allegation of harassment of an employee or of a member of the public in connection with the Company’s activities, he/she should (whether or not a formal complaint has been made) discuss it with the complainant and, report it to the Company’s Equal Opportunities Officer, where it is felt to be appropriate.

Victimisation

Victimisation is a form of discrimination. It occurs when a person treats another person less favourably on the grounds that the person has brought proceedings, given information about or raised a complaint about discriminatory behaviour, or supported someone else's complaint. It would include bullying or intimidating a fellow employee where that employee has raised a grievance about discrimination suffered, for example, on the grounds of sex.

Employee responsibility

Every employee must take reasonable steps to ensure that harassment does not occur and must report any incidents to the Company’s Equal Opportunities Officer. Employees who believe they are the victims of harassment or victimisation may raise the matter with their immediate supervisor and/or the Equal Opportunities Officer without the need to make a formal complaint. However, employees who believe they are victims of harassment or victimisation are encouraged to use the complaints procedure which is part of this Equal Opportunities Policy.

The complaints procedure

Failure to comply with the Company’s Equal Opportunities Policy or to co-operate with it operating effectively is a disciplinary offence which may lead to disciplinary action including the possibility of dismissal.

It is the Company’s aim to resolve any complaints as quickly as possible. All complaints will be treated seriously and with appropriate confidentiality. The complaints procedure is set out below.

Making a complaint

Employees who believe they have experienced or are experiencing any form of discrimination, harassment or victimisation should consider first whether it is appropriate to raise the matter directly with the person concerned to resolve the problem. If it is not appropriate to do so, employees should speak in the first instance to their immediate supervisor or Head of department. If an employee feels unable to discuss the matter with

his/her immediate supervisor or Head of department then the appropriate point of contact is a member of the People Department.

Following initial discussions with the appropriate supervisor, Head of department or a member of the People Department, an employee will be asked to choose whether they wish to use an informal, discreet approach, by, for example, discussing the complaint with the individual who is alleged to have caused offence

If the alleged discrimination or harassment involves a third party not employed by the Company or an employee of such a third party, appropriate action to deal with the problem will be discussed with the person making the complaint.

If the employee is not satisfied with an informal approach, an employee may make a formal complaint, using the Company’s grievance procedure as outlined in the policy headed ‘Grievance Procedure’.

Although the Grievance Procedure will apply in cases of discrimination, the Company may take additional steps, for example, where it is felt that other members of the Company could be at risk if no action is taken. The matter will be dealt with promptly, fairly and impartially. Maximum care will be taken to ensure that the career and reputation of each party is not unjustly affected.

Investigation and meeting

This step will be conducted in accordance with the Grievance Procedure. It may involve hearing detailed accounts from both the alleged discriminator or harasser and the complainant. Other members of staff may also be asked to provide information. Documents, electronic mail and other evidence may be considered. A full record of the progress and outcome of the investigation and any steps taken will be reported to the complainant at the earliest opportunity. Those conducting the investigation will not be parties directly involved in the allegation. You will also be asked to meet with a Senior Manager to discuss the issues raised.

Disciplinary interview

Where a formal investigation has been conducted and where it has been reasonably concluded that some form of discrimination, harassment or victimisation may have taken place, those responsible for such acts will be subject to the Company’s disciplinary procedures, which will be conducted by the next level of management and/or by a member of the People Department who will not have been previously involved.

The outcome of the disciplinary procedures will depend upon the circumstances. Serious acts of discrimination, harassment or victimisation will be regarded as gross misconduct and may lead to instant dismissal. There is a right of appeal against disciplinary action in accordance with the procedure described in the Company’s disciplinary procedures.

Consideration may be given to redeploying either the discriminator/harasser, or the complainant. If redeployment is considered then the wishes of the complainant will normally come first. Where your complaint is about someone other than an employee, such as a contractor, customer, service user, supplier or visitor, the Company will consider what action may be appropriate to protect the complainant and anyone involved pending the outcome of the investigation, bearing in mind the reasonable needs

of the business and the rights of that person. Where appropriate the Company will attempt to discuss the matter with the third party

Employees will be protected from harassment, victimisation or discrimination for making a complaint or assisting in an investigation. Any acts of retaliation or intimidation against an employee will be treated as a disciplinary offence.

An employee who maliciously makes an unfounded complaint will be subject to disciplinary action.

Equal opportunities officer

A senior employee of the Company is appointed Equal Opportunities Officer. The current Equal Opportunities Officer for the Company is the People Director.

The Equal Opportunities Officer will, with the assistance and co-operation of senior management, the People Department and other employees, take steps to ensure universal compliance with the policy.

Monitoring

To ensure that this policy is operating effectively, and to identify groups that may be under-represented or disadvantaged within the Company, we may monitor employees and applicants' ethnic group, gender, disability, sexual orientation, religion and age. Provision of this information is voluntary and it will not adversely affect an individual's chances of recruitment or any decision related to their employment. Analysing this data helps the Company to take appropriate steps to avoid discrimination and improve equality and diversity.

Note that the Equal Opportunities Policy, including the harassment and victimisation policy and complaints procedure, set out above do not form part of employees’ contracts of employment and may be changed by the Company in its absolute discretion at any time.

Sickness

In the event of sickness or injury you must telephone your manager or supervisor, or if this is not possible, arrange for a relative or friend to do so, by 9.30 am on your first day of absence and regularly thereafter if sickness is prolonged. Employees must indicate the reason and probable duration of the absence.

For any absence due to illness or injury of one day or more, you are required to complete a Sickness Declaration form, available as a template from the intranet. In the case of absence which exceeds seven consecutive calendar days, you are also required to obtain a medical certificate from your doctor.

The Company will pay you Statutory Sick Pay as required by law, during any unavoidable absence through sickness. In addition, the Company will continue to pay your basic salary (inclusive of Statutory Sick Pay) when you are absent through sickness or injury on the following basis:

Contracts of employment set out details that are applicable to individual employees. Pro rata arrangements apply to part time employees as well as to employees on short term contracts of less than 12 months in duration. The above applies on a rolling 12 month basis.

Payment of basic salary as above during sickness will be at the Company’s discretion.

The Company reserves the right to review these periods and to withhold payment of sick pay if any absence is not covered by medical certificates. It shall be a disciplinary offence not to provide appropriate certificates for all periods of absence by reason of sickness or injury.

The Company reserves the right to ask for medical certificates for a period of illness which is less than seven days. Furthermore the Company may require employees to attend a consultation with the Company’s doctor. In these cases the costs would be met by the Company.

You are expected to arrange medical appointments outside of working hours if possible, or as near to the beginning or end of the working day as possible. A request for time off for such purposes will be dealt with sympathetically. Your line manager may, at their discretion, request an employee to take the time off work requested as annual holiday entitlement.

Further details on Occupational Sick Pay and Statutory Sick Pay (SSP) are available from the People team.

Please refer to the Absence Policy on the intranet for further information.

Family policies

Family friendly leave policies

The rules and procedures for Maternity Leave, Adoption Leave, Shared Parental Leave and Paternity Leave are complex and changed regularly by the Government. Please inform your Manager and People contact of your intention to take leave as early as possible, and the People team will explain the rules and provide you with guidelines, which are also available on the intranet.

Birth of baby/adoption of child

To congratulate you on the birth of your baby/ adoption of a child (up to 18 years) you will receive a gift from the Company which will be posted to your home address. The gift is Brought to you by From Babies with Love, who donate 100% of their profit to orphaned and abandoned children around the world. Please ensure you inform your People Advisor accordingly. This applies to both female and male employees.

Parental leave/time off for dependants

Parental leave is available for parents who have one year’s continuous service. You are entitled to request up to 18 weeks’ unpaid leave for each child (born or adopted) until that child’s 18th birthday. The leave can start once the child is born or placed for adoption, or as soon as the employee has completed a year's service, whichever is later.

The limit on how much parental leave each parent can take in a year is 4 weeks for each child. Employees must take parental leave as whole weeks (e.g. 1 week or 2 weeks) rather than individual days, unless the child is disabled. A ‘week’ equals the length of time an employee normally works over 7 days.

Employees must give at least 21 days’ notice before their intended start date. If the employee or their partner are having a baby or adopting, its 21 days before the week the baby or child is expected.

Unpaid time off is available for domestic incidents under the Time Off for Dependants policy.

Further information is available from the Intranet/People department.

Flexible working

All employees who have completed 26 weeks’ service have the right to request flexible working under the Equality Act 2010. These requests can include changes to working hours, working time or working location.

For more details please contact the People department.

Working time directive

The stated objective of the Working Times Regulations is to lay down minimum health and safety requirements for the organisation of working time. The points which are relevant to us are:

Maximum weekly working time

A limit of 48 hours over a rolling 17 week period is imposed on average weekly working time. An individual employee may voluntarily choose to work in excess of the weekly working time limit.

Minimum periods of weekly and daily rest and minimum breaks whilst working

Employees are entitled to a daily rest period of 11 consecutive hours and a weekly rest period of 24 hours, together with a daily 20 minute rest period where the working day is longer than 6 hours. The daily rest period may straddle two calendar days.

If you believe that over any given 17 week period you may average more than 48 hours, you should discuss the matter with your line manager or the People team. Further information is available from the People department.

Termination of employment

On termination of employment (be it at the request of the Company or the individual, for whatever reason) the Company is entitled to deduct, as far as possible, from any final monies owing, all debts owed by you to the Company or any member of the CBRE Group, including but without limitation:

– The balance outstanding of any holiday excess

– Season ticket loan

– Training and development loan

– Other loans advanced by the Company

– deductions in respect of tax or National Insurance

– outstanding car insurance excesses

– repairs to cars returned to the Company in a damaged condition

car deductions where excess lease payments are made over the entire lease period

– parking or congestion charge fines

If there is still a balance outstanding, you should make a direct bank transfer to the Company before you leave and, if you do not, the Company reserves the right to deduct the sum owed by you from any pension refund or, if necessary, to take legal proceedings for recovery.

Your P45 and final payslip will be sent to your home address by our payroll services provider.

On termination of your employment, you must return to your manager all original and copy documentation, files and correspondence relating to the Company’s affairs, together with any vehicle, credit cards, security cards, IT equipment, Blackberry, telephones, books, Employee Handbook, keys, equipment or other property belonging to the Company.

Disciplinary code

It is in the interests of the Company that everybody conforms to established standards of conduct and observes the Company’s rules and procedures and the rules set out by the regulators in the environment in which we operate. Please refer specifically to the

intranet for our Code of Conduct and Compliance Rules. A serious infringement of these will be regarded as gross misconduct and will render you liable to immediate dismissal. Examples of what the Company would regard as gross misconduct are given below, although these are not exhaustive:

– A breach of statutory and/or regulatory rules, as amended from time to time.

– A breach of the Conduct Rules under SMCR

– Serious infringements of established standards of conduct at work, such as misappropriation of property, theft, fraud, physical assault, being drunk or under the influence of illegal drugs, or breach of the Compliance Rules

– Criminal offences

– Violation of the Company’s Electronic Communication Policy

– Behaviour which disregards the Company’s Equal Opportunity or Harassment Policy or other Company procedures and policies

– Violating health and safety rules or practices or engaging in conduct that creates a health, safety or environmental hazard

– Disclosure of confidential information about CBRE or its employees, clients or suppliers

– Engaging in business outside the Company during working hours without written permission of the Managing Director

– Breach of sections A2.1.b of the Estate Agents Act (1979)

– Engaging in business, at any time, that is in competition with or prejudicial to the Company

– Behaviour to the Company’s clients, suppliers or advisers which is prejudicial to the Company or which would in any way damage the Company’s standing with clients or members of the public

– Unauthorised absence from work

The Company has a disciplinary procedure, a copy of which is available from the People department or the Intranet.

Grievance procedure

Every employee in the Company has the right to raise a grievance relating to their employment. The Company has a grievance procedure, a copy of which is available from the People department, or the intranet.

Data privacy and protection

In this clause, the terms ‘personal data’, ‘special categories of personal data’ and ‘processing’ each have the meaning attributed to them by the UK Data Protection Act of 2018, the UK General Data Protection Regulation (UK GDPR) and associated laws and regulations, including the EU General Data Protection Regulation (EU GDPR). Further, in this clause, ‘CBRE’ refers to the CBRE Group Inc. global corporate group of companies.

The Company holds a variety of information on employees, clients, suppliers and professional advisers to the business and has an obligation to comply with the UK GDPR, the EU GDPR, and all EU Data Protection Laws and, to the extent applicable, all data protection and data privacy laws and regulations of any other jurisdiction (collectively, Data Protection Legislation).

The CBRE Group has enacted global policies related to the processing of personal data, which can be accessed on the Company Intranet, by clicking the following link:

https://www.cbre.com/about-us/global-web-privacy-and-cookie-policy including Global Policy 6.22: Data Privacy.

Your personal data

This below explains how the Company collects, uses, transfers, and discloses Personal Information relating to Company employees and contractors.

“Personal Information” here refers to information capable of identifying you, your spouse, dependents /family members and other persons, when used alone or in combination with other information. The Company is committed to protecting your Personal Information. It’s your information, it’s personal, and we respect that. We also want to maintain the trust and confidence of all employees.

Personal Information We Collect and Sources

a. Categories of Personal Information We Collect

Where we may lawfully do so under applicable law, we collect the following categories of Personal Information directly from you or from other sources, (for more information on data sources, see Sources from Whom We Collect Personal Information, below).

– Employee Authentication Information: such as your work email, password, authentication token, and CBRE employee ID number.

– Basic data: such as your name, gender, place of birth, date of birth, current nationality, any prior nationalities, language(s) spoken, title, organization, job responsibilities, phone number, mailing address, email address, contact details and information about family life (excluding special categories of data) including your

marital status, spouse or partner, other family members, children, dependents, hobbies and interests.

– Contact and Employment Information: such as your worksite addresses, business telephone number, business email address, job title, and name and email address of your supervisor.

– Professional information: such as educational and employment history, relevant skills and/or qualifications, professional certifications and affiliations, compensation history (where allowed by law) and any other information included in curriculum vitaes/resumés, online professional profiles, and job applications.

– Job Applicant Evaluation Information: such as the opinions of references you provide, willingness to relocate, your current notice period, expected salary, credit history, and, where allowed by law: psychometrics and/or skills test and assessment results, pre-joining medical questionnaire, reference letters, information about your outside activities or family relationships that may give rise to a conflict of interest and information about criminal offense, conviction, pending investigations and administrative sanctions.

– Employee Onboarding Information: such as information necessary to form an employment or contractual relationship with the applicant and for legal compliance (such as signature, national insurance number, copies of your national ID card, driving license, passport, residency permits, and visas demonstrating the Right to Work), to processing payroll and provide employee benefits (such as employment start date, bank account information, tax withholding elections, existing private medical insurance, private medical insurance application details and beneficiary information), and disability or other data (where allowed by law) needed to provide workplace accommodations.

– Employee Relations Information: such as records and correspondence relating to redundancies, disciplinary actions, capability hearings, sickness/absence hearings and grievances, litigation documentation, resignation letters, settlement agreements, without prejudice correspondence, garden leave documentation, training attendance records, training certificates, termination letters, exit interview notes, recognition or exceptional award letters, performance management plans and succession planning exercises.

– Benefits Information: such as information about stock options, stock grants, and other awards, pension contributions, health insurance, incentive schemes and car allowances.

– Special categories of data: such as religious or other beliefs, racial or ethnic origin, sexual orientation, health data such as medical questionnaires and doctor's notes, and details of trade union membership where allowed by applicable law and if you choose to provide it.

– Diversity Data: such as gender/gender identity, race, ethnicity, sexual orientation, military/veteran status, and disability status (only where allowed by applicable law and if you choose to provide it). If you do not wish to provide your personal diversity data, please select the ‘Prefer not to say’ option and we will respect that decision.

Biometric, Electronic Identifiers, Security and Monitoring: such as photographs, iris recognition, video and CCTV recordings, Instant Messenger Recordings or messages, email monitoring and entry and exit records, geo-location data, usernames and passwords, and internet usage history

– Working Time and Leave: such as documentation relating to annual leave, hours worked, days worked, flexible working arrangements, jury service leave, working patterns, pensionable employment, disability, sabbatical leave and reserve forces

– Family Related Data: such as documentation and details related to life assurance/death in service nomination details, maternity, paternity and adoption leave, compassionate leave, marital status and childcare reimbursement/vouchers.

– Client service data: such as Personal Information received from clients in respect of employees, customers or other individuals known to clients, invoicing details and payment history, and client feedback.

– Marketing data: such as your participation in conferences and in-person seminars, credentials, associations, product interests, and preferences.

– Compliance data: such as Government identifiers, passport or other governmentissued identification documents, beneficial ownership data, and due diligence data.

– Self-Certification Information: such as date, location of the CBRE worksite you wish to access, confirmation of your compliance with Workplace Infection Riskmitigation protocols, and Special Category health-related data such as the absence of Workplace Infection Risks symptoms (e.g., Covid-19-related symptoms).

– Physical Access Data relating to your visits to our premises, such as your name and date and time of your visit.

– Miscellaneous Data: such as repayment agreements for relocation, structure charts, tuition reimbursement support documents, car lease documentation, cycle to work documentation reference letters for mortgages and tenancies, references for travel and visas, expenses documentation, immigration documentation, salary planning merit data, employee bonus information, employment probation details, changes to pay and conditions, agreements for relocation, promotion, demotion information and TUPE data, and information about unspent points or fines on your driving license.

b. Special Categories of Personal Information

To the extent we may lawfully do so under applicable law, we may collect and process categories of Personal Information relating to you which (depending on the applicable legal regulations and law to which you are subject, such as in the EU/EEA and UK) enjoy special protection by qualifying as special categories of Personal Information, sensitive Personal Information or similarly. Examples of such special categories of Personal Information include the Sensitive Data described herein. Where we may lawfully do so under applicable law, as part of our employment responsibilities, we may collect information (also known as special category or sensitive Personal Information in some jurisdictions)

c. Sources From Whom We Collect Personal Information

We collect and process Personal Information:

– when you contact the People Department directly, whether in person, via telephone or by email and provide your personal data as a necessary part of your enquiry;

– when you apply for a vacancy internally;

– when we collect data through the implementation of any CBRE People employeerelations policy e.g., CBRE’s disciplinary policy;

– in the course of managing your employment with the Company, for example, payroll administration;

– when you input your Personal Information on myPortal (CBRE’s Employee Self Service Platform (PeopleSoft)) or CBRE’s internal staff directory;

d. Consequences of Not Providing Personal Information

If you fail to provide certain information when requested, we may not be able to perform our contract with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

e. Use of Personal Information and Legal Bases

The purposes for which we use your Personal Information and the legal bases for such processing are as follows:

In broad terms, processing Company employee’s Personal Information is either a statutory or contractual requirement and/or necessary to fulfil a legal obligation or to meet a legitimate interest. The Company may also process employee’s Personal Information to perform tasks in the public interest and in emergency situations, such as to ensure the safety of employees or other individuals, or to save a life. In limited circumstances, the Company processes employee data based on consent.

The Company only relies on consent as a basis for processing your Personal Information for data processing not connected with your employment contract. For example, when you complete surveys that we use for administrative purposes. In such cases, you have the right to withdraw your consent at any time, without affecting the lawfulness of the prior processing based on consent.

Processing your Personal Information is necessary for pursuing the Company’s legitimate interest in monitoring and administering our human resources, the operation of our business including managing our relationships with third parties and providing services to clients. For detailed information regarding the purposes for which each category of your Personal Information may be collected, used, transferred, and disclosed, please see below.

– To manage our workforce and personnel generally, we collect and use your Employee Authentication Information, Basic Data, Contact and Employment Information, Benefits Information, Special categories of data, Professional Information, Job Applicant Evaluation Information, Employee Onboarding Information and Employee Relations Information. We process this Personal Information where necessary for Employment Law purposes and for the overriding legitimate business interests of the Company or based on your consent (if required by law).

–

To ensure the smooth operation of our business, we process your Basic data and Contact and Employment Information. We process this Personal Information where necessary for the overriding legitimate business interests of the Company or based on your consent (if required by law).

– To provide IT Support including hosting, we process Contact and Employment Information and Employee Authentication Information. We process this Personal Information where necessary for the overriding legitimate business interests of the Company or based on your consent (if required by law).

– To ensure compliance with the Company’s legal and other requirements, we process Contact and Employment Information, Family Related Data, Self-Certification Data and Compliance Data. We process this Personal Information based on the Company’s legal obligations, for other overriding legitimate business interests of the Company (described in more detail below), and/or based on your consent (if required by law).

– To manage access to our premises and for security purposes, we use physical access data. We process this Personal Information where necessary for the overriding legitimate business interests of the Company or based on your consent (if required by law).

–

To communicate with you about workplace health and safety issues, including Incidents, emergencies, Self-Certifications and Workplace Infection Risks, where necessary, we process your Contact Information. We process this based on the Company’s overriding legitimate business interests (described in more detail below) and/or based on your consent (if required by law).

– To communicate with your supervisor where legally permissible to do so about Observations (workplace safety concerns) and any associated Incident (a workplace injury, illness, or health-related event) you have reported, witnessed or been involved in, Workplace Infection Risks to which you may have been exposed, and absences from work resulting from Incidents or Workplace Infection Risks, where necessary, we process your Employment Information, Observation Information, Incident Information and Self-Certification Information. We process this Personal Information based on the Company’s legal obligations in the fields of employment or occupational health and safety laws, for other the overriding legitimate business interests of the Company (described in more detail below), and/or based on your consent (if required by law).

– To manage our business operations and administer our client relationships, we use Basic Data, Sensitive Data, Registration Data, Marketing Data and Client Service Data. We process this Personal Information where necessary in order to perform our obligations under our contracts with our clients (e.g., issuing and processing invoices) and suppliers (e.g., managing the supply of goods and services).

– To reduce unsafe and unhealthy workplace conditions, process property damage claims, and report to regulators, where necessary, we process Observation Information. We process this Personal Information based on the Company’s legal obligations in the fields of employment law and occupational health and safety law, for other overriding legitimate business interests of the Company (described in more detail below), and/or based on your consent (if required by law).

–

To create workplace health and safety metrics to measure the Company’s performance in providing employees and contractors with a safe workplace, reduce Incidents and Workplace Infection Risks, process workers’ insurance claims, and report to regulators, where necessary, we process Incident Information and sensitive Personal Information relating to Workplace Infection Risks. We process this Personal Information based on the Company’s legal obligations in the fields of employment law and occupational health and safety law, for other overriding legitimate business interests of the Company (described in more detail below), and/or based on your consent (if required by law)).

– To establish, exercise or defend our legal rights, to comply with lawful government requests for disclosure of Personal Information or otherwise to comply with legal obligations, we use any of the Personal Information we collect about you where legally permissible to do so. We process this Personal Information where necessary to comply with the Company’s legal obligations or for other overriding legitimate business interests.

– To achieve lawful Diversity Equity & Inclusion objectives, we may (where allowed by law and to the extent possible in an aggregated, pseudonymized format) collect Diversity Data you choose to provide as necessary to comply with applicable employment law obligations, for the overriding legitimate business interests of the Company, and for reasons of substantial public interest (such as reviewing and monitoring equality of employment opportunity and treatment of job applicants), or based on your consent (if required by law). We protect Diversity Data with suitable and specific measures (such as encryption) to safeguard the fundamental rights and interests of the applicant providing such Diversity Data. We will not, and do not, use Diversity Data to make Talent Acquisition or other employment-related decisions about you or other individuals.

f. Legitimate Business Interests

To the extent, the Company relies on its overriding legitimate business interests for the processing of your Personal Information, such business interests are in particular:

– to manage our business operations.

– To manage our relationship with our employees, including, where applicable, our contractual obligations to our employees.

– providing advice and services to clients.

– managing our contractual relationship with clients and to allow clients to manage their relationship with us.

– establishing, exercising or defending our legal rights and claims.

To the extent any of the processing purposes listed above require the processing of Special Categories of Information, such processing may in particular be permitted or required under applicable law as the processing is necessary to carry out certain obligations or exercise certain rights in the field of employment, social security and social protection, to establish, exercise or defend a legal claim, for reasons of substantial public interest or of public interest in the area of public health, and other necessary objectives or based on your consent (if required by law). We will collect and process those categories of personal information only where allowed by law, subject to any

restrictions and additional safeguards as required by law and where relevant to and necessary in relation to your employment.

g. Automated Decision-Making

the Company does not process any personal data it collects to make automated decisions.

Sharing of Personal Information

Where we can do so lawfully under applicable law, the Personal Information we collect may be shared and processed with the following categories of recipients, some of whom may be located in a country that does not provide an adequate level of data privacy and protection rights as your home country, as necessary for the purposes identified in Section 3 – Use of Personal Information and Legal Bases, above. The Company has in place appropriate safeguards regarding internal Personal Information sharing. See International Data Transfers below for more information. To the extent possible, Personal Information is shared in an aggregated, pseudonymized or anonymized format.

a. Internally with Other CBRE Entities

CBRE is a global firm and the Personal Information we collect, or you provide may be shared and processed with CBRE entities as necessary for the purposes identified in Section 3 – Use of Personal Information and Legal Bases, above. Access to Personal Information within CBRE will be limited to those individuals who have a need to know the information for the purposes described in Section 3 – Use of Personal Information and may include your managers and their designees, personnel in the People, IT, audit, finance, legal and compliance, data processing departments or service providers. In particular:

– When you log into your CBRE account, use www.cbre.com or any of our applications , CBRE, Inc. and other CBRE entities employing site administrators and digital and technology and systems support and management staff (referred to as data processors in some jurisdictions) will process certain elements of your Personal Information in order to manage your access to, maintain, and improve the functionality of the site. CBRE, Inc. and these CBRE entities employing such individuals may be located outside your home country.

– As part of CBRE’s responsibilities as an employer, CBRE's global matrix structure may require that your Personal Information (including, Sensitive Data) is transferred to other CBRE entities outside your home country where other CBRE employees who are responsible and accountable for managing your employment with CBRE are located, including employees in your business line or sector, and our People, Quality, Health, Safety and Environment, Global Security and Crisis Management, and Legal & Compliance departments.

– Where legally permissible to process and transfer Sensitive Data outside your home country, and if you provide it, your Sensitive Data may be shared with other CBRE entities outside your home country. To the extent possible, we will share such data in an aggregated, pseudonymized format.

– In order to facilitate communication, all personnel within CBRE will have access to your business contact information, such as name, position, workplace telephone numbers,

addresses and email addresses.

b. With Third Parties

The potentially relevant third parties including:

– Service Providers who provide services to the Company and/or its employees, or assist us with insurance claims processing and benefits, IT, cyber security and data hosting providers.

– Clients and suppliers in managing our relationships with them in the course of our business operations.

– Insurers, brokers and/or loss adjusters as necessary to file and manage property and workers insurance claims and benefits.

– Owners and operators of sites at which Observations, Incidents, and Workplace Infection Risks Occur and with whom the Company has a contractual or other legal obligation to share your Personal Information, and only to the extent legally permissible to do so.

– Consultants and advisors who assist us with legal, regulatory, and business operations activities, such as legal counsel, compliance consultants and business auditors.

– Governmental Regulators as necessary to comply with the Company’s legal obligations in the fields of employment law and occupational health and safety law in certain countries.

– Diversity & Inclusion (Governmental) Regulators, as necessary to comply with the Company’s legal obligations in the area of employment law in certain countries; we may share Diversity Data on an aggregated, de-identified basis only.

– Business partners in case of a merger or sale, such as if the Company is merged with another organization, or in the event of a transfer of our assets or operations.

Legally Compelled Disclosure

We may be required to disclose your Personal Information to governmental and regulatory authorities, law enforcement agencies, courts and/or litigants when legally compelled to do so, for example, in response to a court order, summons/subpoena or other lawful, legally binding request, including to meet national security or law enforcement agencies requirements, or in connection with legal proceedings or similar processes as necessary to exercise or defend our legal rights.

the Company is committed to not disclose your Personal Information in response to an international court order or a summons or subpoena or other legal obligation, unless we are legally compelled to do so under applicable law. In particular, CBRE, Inc. has assessed and is of the view that neither it nor its US subsidiaries qualify as a provider of electronic communication service, as defined in 18 U.S.C. § 2510, nor a provider of a remote computing service, as defined in 18 U.S.C. § 2711, and thus US public authorities cannot issue a legally binding demand for disclosure of data under Section 702 of the US Foreign Intelligence Surveillance Act ("FISA 702") upon CBRE, Inc. or its US subsidiaries. In case CBRE nevertheless receives at some point a disclosure demand for Personal Information under FISA 702, we will publish a Transparency Report on cbre.com and our

EEA websites (see our Schrems II statement). All personal data transferred by the Company to the US is encrypted in transit.

Retention of Personal Information

We will retain your Personal Information only for as long as required to satisfy the purpose for which such information was collected, unless otherwise required by law or regulation to be retained for a longer period. the Company will take reasonable steps to ensure that the Personal Information we process is reliable for its intended use, accurate, and complete as necessary to carry out the purposes described in this Notice. the Company retains employee data based on statutory retention periods, commonly recommended data retention periods and for the period necessary to fulfil the purposes outlined in this Notice, unless a longer retention period is required or permitted by law. These retention periods are set out in the Company’s data retention policy/schedule. Please contact the Company’s group data protection officer for a detailed copy of this policy/schedule. Furthermore, the Company may need to retain your personal data for statistical purposes. In such cases, the data retention will be carried out with appropriate safeguards, to ensure that your data is fully protected. Should you require further information as to the retention period, please do not hesitate to contact us.

How We Secure Personal Information

We implement appropriate technical and organizational security measures to safeguard the Personal Information we collect and process about you against loss and unauthorized alteration or disclosure. The information you provide is encrypted in transit and at rest. We utilize role-based access controls to limit access to your Personal Information on a strict need-to-know basis consistent with the purposes for which we have collected such information. We utilize anti-malware and intrusion detection systems to guard against unauthorized access to our network, and we have an incident response plan in place to quickly respond to any suspected leak or breach of Personal Information.

Where we share your Personal Information with our service providers, we have assessed that their technical and organizational measures provide an appropriate level of security.

International Data Transfers

Depending on the recipients (see Sharing of Personal Information above), your Personal Information may be processed and hosted in countries other than your home country, such as e.g., United States, United Kingdom, Australia, Philippines, Singapore, and India. Those other countries may have less stringent data protection laws than the country in which you reside, in which you initially provided the information and/or in which your information was originally collected.

In case of international data transfers, we will protect your Personal Information as required by all applicable data protection laws.

a. EEA and UK to Non-EEA Data Transfers

With respect to international data transfers initiated by the Company from the European Economic Area ("EEA") or UK to recipients in any non-EEA jurisdictions,

– some recipients are located in countries which are considered as providing for an adequate level of data protection under EU law (or UK law, as applicable). These transfers do not, therefore, require any additional safeguards under EU (or UK, as applicable) data protection law.

– other recipients are located in countries not providing an adequate level of data protection under EU or UK law, such as e.g., the US or India and, where required by law, we have implemented appropriate safeguards, such as EU Standard Contractual Clauses, and/or are relying on binding corporate rules of the recipient or an appropriate derogation. Where applicable, we implement supplementary technical and contractual safeguards. Under applicable law you may have the right to ask for further information on such appropriate safeguards (see Section 9 - Contact below). As stated above (see Legally Compelled Disclosures), CBRE, Inc. has assessed and is of the view that US public authorities cannot issue a lawful disclosure demand for personal data under FISA 702 upon CBRE, Inc. or its US subsidiaries. All personal data transferred by the Company to the US is encrypted in transit.

Your Data Privacy Rights

Depending on the legal regulations in your country and the applicable laws to which you are subject, you may have all or some of the following rights set out below and may submit a request(s) to exercise any such rights through our Data Subject Rights Portal or by contacting us at dsr@cbre.com. Irrespective of the CBRE entity that is responsible for the processing of your Personal Information, you may use such centralized contact details and CBRE will ensure that the responsible CBRE entity receives your request and addresses it promptly as required by applicable law. CBRE will respond to your request comprehensively, even if you do not identify the particular CBRE entity against whom you make the request.

– Right of access: You may have the right to obtain confirmation from CBRE as to whether your Personal Information is being processed, and, where that is the case, to request access to your Personal Information. You may have the right to obtain a copy of your Personal Information undergoing processing. For additional copies requested by you, CBRE may charge a reasonable fee based on administrative costs.

– Right to rectification: You may have the right to obtain from CBRE the rectification of inaccurate Personal Information concerning you.

– Right to erasure (right to be forgotten) or anonymization: You may have the right to ask us to erase (or in some jurisdictions, anonymize) your Personal Information. In some jurisdictions, this right may be limited to deletion or anonymization of data that is unnecessary, excessive, or unlawfully processed, or deletion of data that is processed based on your consent.

– Right to restriction of processing: You may have the right to request the restriction of processing your Personal Information.

– Right to data portability: You may have the right to receive your Personal Information which you have provided to CBRE in a structured, commonly used, and machine-readable format and you may have the right to transmit that Personal Information to another entity without hindrance.

Right to withdraw consent: If we rely on your consent for any Personal Information processing activities, you have the right to withdraw or revoke this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal. This right to withdraw consent applies to consents given for marketing and profiling purposes, if any.

– Right to object: Under certain circumstances, you may have the right to object, on grounds relating to your situation, at any time to the processing of your Personal Information by CBRE, and CBRE can be required to no longer process your Personal Information unless CBRE demonstrates compelling legitimate grounds for the processing which override your interests, rights, and freedoms or for the establishment, exercise or defence of legal claims. The right to object may not exist if the processing of your Personal Information is necessary to take steps prior to entering into a contract or to perform a contract already concluded.

– Right to request an explanation of our processing activity of your Personal Information

– Right to information on the possibility to withhold consent and information on the consequences of doing so.

– Right to information on third parties with whom we have shared your data.

– Right to lodge a complaint with the competent data protection authority in your home country or in the country in which the responsible CBRE entity is located, in particular with respect to the result of automated decision-making. A list of European Union Data Protection Authorities is available from the European Data Protection Board.

Contact

a. General Inquiries

You may contact CBRE’s Global Data Privacy Office (“GDPO”) at Privacy.Office@cbre.com or by writing to us at 321 North Clark Street, Suite 3400, Chicago, Illinois 60654, Attention: Global Director, Data Privacy. You may also e-mail us via the GDPO at EMEAPrivacyDirector@cbre.com or write to us at Henrietta House, Henrietta Place, London W1G 0NB, United Kingdom, Attention: EMEA Director, Data Privacy

You may also contact your local People team. You may raise questions or concerns about the GDPO or your local People team to CBRE’s Ethics & Compliance department via the CBRE Ethics Helpline

b. Data Protection Officers

In some countries, CBRE has appointed a Data Protection Officer (“DPO”), whom you may contact with questions or concerns about how CBRE processes your Personal Information. Contact information for our DPO’s in the European Union and the UK are available in our Global Privacy and Cookie Notice

c. EU and UK Representative

We have appointed a representative for the responsible CBRE entities located outside of the EEA and UK that process your Personal Information subject to the EU General Data Protection Regulation and UK data protection law. The representatives contact details are available in our Global Privacy and Cookie Notice.

The above information is published in the Employee Privacy Notice, available on the CBRE Global Data Privacy Office Intranet Page. Further information relating to Data Protection, including your rights under data protection legislation, may be found on the Company Intranet.

Your obligations

You must only process personal data (whether related to clients, third parties, such as tenants, or other employees of the Company) for the following purposes:

– as instructed directly by the relevant Data Controller (including but not limited to clients and, with respect to CBRE employees, CBRE);

in accordance with the relevant contractual data processing terms or data processing agreement;

– as set out in the applicable Privacy Notice;

– protecting and promoting CBRE’s legitimate interests and objectives (for example ensuring site security, managing fraud/money laundering prevention), subject to consultation with CBRE management, Legal & Compliance, and or the CBRE Global Data Privacy Office (GDPO); and

– to fulfil CBRE's contractual and other legal obligations

Use of personal data: If you intent to use personal data for purposes other than as described above, you must consult with your supervisor/line manager and, where appropriate, the CBRE GDPO, and insure that CBRE has a lawful reason for using the personal data in such manner, and that all requirements under applicable Data Protection Law have been satisfied.

If, whether under the instruction of a Data Controller or otherwise, you are processing or using personal data in a way which you think an individual to whom the data relates (Data Subject) might think is unfair or which you believe does not meet the abovedescribed requirements, please contact your line manager or the GDPO before continuing to do so..

A breach of this policy may be treated as misconduct and could result in disciplinary action including in serious cases, dismissal.

A member of Staff who deliberately or recklessly misuses or discloses personal data held by CBRE without proper authority or other than as described in this section may also be guilty of a criminal offence.

You must –

– undertake the compulsory data protection training within a month of starting your new role at CBRE and annual refresher training, or as otherwise assigned to you;

– familiarise yourself with the Data Protection Policy set out in the People intranet and/or Employee Handbook;

– familiarise yourself with CBRE’s Employee Privacy Notice;

– take all reasonable steps to prevent the unauthorised disclosure of or access to personal data and special categories of personal data you process or transfer during your employment;

– comply with the UK GDPR, the EU GDPR and all other Data Protection Laws when processing any personal data and special categories of personal data during your employment;

– share personal data on a “need to know” basis only;

– take all reasonable steps to ensure that any third party to whom you transfer any personal data and special categories of personal data not only complies with relevant Data Protection Laws but also prevents it from disclosure to or access by unauthorised persons;

– be able to recognise when someone is exercising their rights in their Personal Data in order that you can refer the matter to the GDPO.

– inform your line manager and/or the GDPO immediately on becoming aware of any actual or suspected breach of the requirements of data protection legislation; and

– inform the Company immediately of any changes to your personal data.

Electronic communication policy

The purpose of this policy is to ensure the proper use by employees of the Company’s various electronic communications systems, including its computers, Blackberrys, desk and mobile telephones, iPads, voice-mail, internet access and e-mail systems (collectively “electronic communication systems”). The Company’s electronic communication systems are tools for business communication, and all employees have the responsibility to use these resources in an efficient, effective, ethical and lawful manner for the benefit of the Company.

Violations of this policy may result in disciplinary action, including the possibility of dismissal and may subject the violator to legal action.

All computers, mobile telephones and iPads issued by the Company, voice-mail, Internet and e-mail accounts maintained by CBRE Investment Management, are the sole property of CBRE Investment Management. CBRE Investment Management has the right to monitor any employee’s computer, mobile telephone and iPad issued by the Company, voice mail, e-mail accounts and Internet use to help assure compliance with this policy, for training purposes, or to determine if the systems are being used for other than legitimate business reasons. Employees have no individual right of privacy regarding any information created, stored or sent in or by the Company’s computer, mobile telephone, iPad, voice mail and/or e-mail systems or Internet access systems.

The following actions and uses of CBRE Investment Management’ electronic communication systems are strictly prohibited and may result in disciplinary action, including termination of employment:

The access, storage, creation and exchange of material that is or could be considered to be offensive, harassing, obscene or threatening, or which otherwise violates any law or Company policy

The intentional creation or dissemination of computer viruses

– The unauthorised exchange of proprietary information, trade secrets or any other privileged, confidential or sensitive information, relating to CBRE Investment Management, a client or the business of these parties. (Caution should be taken to ensure that messages are addressed to the appropriate recipient; it is easy to inadvertently address e-mail messages incorrectly. Confidential messages should include a warning regarding accidental transmission to an unintended third party. Please remember that e-mails are legally binding)

– The creation and exchange of advertisements, solicitations, sale of tickets or personal property, joke and joke attachments or chain letters

– The creation and/or exchange of information in violation of any copyright laws

– Registration on mailing lists without proper authorisation. (Subscription to such a service can result in an overload of received messages directly impacting the performance of the e-mail system)

– Messages read or sent from another user’s account except under proper delegation arrangements

– Activities that cause the wasting of networked resources, including the effort of users involved in the support of those resources

Users receiving material, or becoming aware of material or activities, in violation of the above policies should immediately report the incident to their immediate supervisor or manager who should report such violation to the Managing Director.

– All users of CBRE Investment Management’ e-mail systems should observe the following practices:

– Users must not compromise the privacy of their password by giving it to others or exposing it to public view. Passwords should be changed on a regular basis.

Users should retain messages only if relevant to the business. Back-up copies of e-mail messages will be retained by CBRE Investment Managements’ e-mail system.

– Address messages to recipients who need to know. (Messages sent unnecessarily can impact the system and user performance.)

– Construct messages professionally (spelling, grammar) and efficiently (subject, field, attachments). Use prudence sending attachments in order to minimise network load.

– E-mail communications should follow the same standards expected in written business communications and public meetings.

Incidental personal use of the e-mail system is permissible so long as it does not interfere with the performance of the e-mail system or the accomplishment of the user’s responsibility and does not otherwise violate the above restrictions.

Use of all electronic communications systems must be in line with all published standards, as issued from time to time.

You will be required to sign a declaration during your induction process to confirm you have received and read the policy, and that you will abide by its content.

Confidentiality

In the ordinary course of your employment you will be exposed to information about the business of the Company, its clients and other members of the CBRE Group which is confidential or is commercially sensitive and which may not be readily available to competitors or the general public and which if disclosed will be liable to cause significant harm to the Company or members of the CBRE Group. Confidentiality provisions are therefore necessary and reasonable to protect the legitimate interest of the Company and members of the CBRE Group.

Consequently you must not, whether during or after your employment, except as authorised or required by your duties as an employee of the Company, reveal (whether deliberately or through lack of care or diligence) to any person, Company or organisation or otherwise make use of any of the trade secrets, secret or confidential operations, processes or business methods or any information (other than that within the public domain) concerning the organisation, business, finances, transactions or affairs of the Company or its clients and members of the CBRE Group.

Government Agencies

This [Handbook] does not limit Employee’s ability to communicate with any government agencies, including the US Securities and Exchange Commission, or otherwise participate in or fully cooperate with any investigation or proceeding that may be conducted by any government agency, including providing documents or other information, without notice to or approval from CBRE.

General administration

Travel policy

CBRE Investment Management expects all employees to use the most cost-effective means of travel, to book as far in advance as possible, to exercise common sense when arranging overnight accommodation, and to use our travel provider Chambers Travel’s online booking tool for all travel.

A traveller profile needs to be completed on the CBRE Travel portal before the service can be activated.

Costs of accommodation, visas, car hire, public transport and taxis should be covered by employees and will be repaid through the expense process, per the policy guidelines stipulated below.

The Company’s travel policy applies to all employees and relates to all travel on Company business.

Each business line has designated travel bookers who can assist with the process. General travel to and from your normal place of work, for example One New Change, is not a claimable expense.

Travel insurance

CBRE Investment Management has travel insurance in place to cover all staff whilst travelling outside the UK on Company business. Some restrictions are in place and the policy excludes normal commuting. The policy is available on request from the CBRE Investment Management Finance Department.

Travel agent

CBRE Investment Management use Egencia for all business flights, trains and hotels.

Contact Numbers0871 330 7133

Travel portal https://www.egencia.co.uk

Email traveladmin@cbre.com

Customer servicecustomer_service@egencia.co.uk

Loss of property / contents insurance

Any article found on the Company’s premises should be promptly handed in to the Office Manager.

The Company’s Contents Insurance does not cover loss or damage to your personal belongings or cash. In particular, do not leave handbags, wallets or other valuables in

unattended offices or cloakrooms. Keys are available for all cupboards from the Office Manager.

Dress code

All employees are expected to dress smartly in a manner appropriate to an office where clients are regular visitors, and to reflect the professional, business-like approach of the Company. CBRE Investment Management have a dress down policy on Friday’s when smart casual wear can be worn if employees have no client meetings. Guidance on the dress down policy is available from the Office Manager and can be found on the CBRE IM Intranet.

Security

A security card will be issued to all employees by the Office Manager on their first day. It is essential that you use this at all times to gain access to the building. General access is between 8.00 am and 6.00 pm Monday to Friday. Access outside these hours or at weekends should be arranged in advance with the Office Manager. If you lose your security card or key at any time, you can be charged £10 for a replacement. The access pass policy can be found on the CBRE IM Intranet.

On leaving the Company, your security card should be returned to the Office Manager. Visitors/contractors must be escorted by a CBRE Investment Management employee and must display a visitor’s badge. Always inform Reception in advance of any expected visitors.

Expenses guidelines

Financial authorisation

The Company has established specific authority levels for the approval of personal expenses and the purchase of items or services required for the Company. Fuller details of these authorisation procedures can be obtained from your Head of Department or Finance.

Expenses

All expenses should be submitted using the MyFinance system. Guidance is available from the Finance Department if required. Claims will be settled direct into your bank account on a weekly basis.

All expenses must be claimed within three months of being incurred, otherwise they will not be paid.

Receipts should be attached with the VAT number of the suppliers in all possible cases. Internet receipts are not considered proof of purchase, a copy of your bank statement will be requested.

Responsibility & control

Each year budgets for travel and entertaining are set and your Department Head or Managing Director will have responsibility for your Department’s travel and entertaining budget, ensuring budgetary control and compliance with your Department’s own internal guidelines.

Travel and entertaining expenditure will be monitored centrally on a Department and individual basis to ensure expenditure does not exceed reasonable levels.

Staff entertaining

All staff entertaining must be approved by the appropriate Managing Director.

Client entertaining

The Managing Director and Senior Directors will control the budget and expenditure for any event-based client entertaining, whether organised as Company's or Department function.

Car & mobile phones

Mobile phones may be provided for business use with the authorisation of your Head of Department. Any excessive personal usage will be payable by the employee. Personal mobiles are to remain switched off during office hours other than where they are being used for business purposes.

Please note that under no circumstances should mobile phones be used when driving. On the advice of the CBRE Legal and Health & Safety advisers, the use of hands free mobile phones whilst driving on Company business is strongly discouraged. Hands free kits will not be supplied or fitted into Company owned vehicles, nor will the Company pay for these kits to be fitted into an employee’s own car.

Technology queries

All technology queries should be directed to the IT personnel located in our One New Change office, this includes computer hardware and software, printers and telephones (including mobiles).

Intranet/Unite

We have a CBRE IM intranet site that provides up to date information on the Company such as the latest business development, client information, Department information, CBRE Code of Conduct, Business Management System, Standards of Business Conduct, Peoplefinder, CRM, this employee handbook, internal vacancies, social activities and lots more. There are also links to other useful sites.

Health & safety

Introduction

It is the policy of CBRE Investment Management to promote high standards of health and safety which will lead to the avoidance of, or reduction in, risks to health and safety, and to ensure that compliance with the Health and Safety at Work Act 1974 (HASAWA) and associated legislation is achieved. All employees, whatever their level, have a duty to take care of themselves and others who may be affected by their acts or omissions. Any potential hazards should be reported, as appropriate.

CBRE Investment Management’ Health & Safety Policy can be found on UNITE and you should take time to read and understand its contents. The Policy outlines our commitment to health, safety and welfare.

The CBRE Health & Safety Arrangements Policy apportions specific health and safety responsibilities across the organisation, which will go some way to ensuring employee health, safety and welfare and that of anyone else who may be affected by our activities.

The main source of these statutory legal requirements is the Health & Safety at Work Act 1974 [HASAWA], whose requirements were made more specific by the Management of Health & Safety at Work Regulations 1999 [MHSWR].

Employer responsibilities

HASAWA requires employers to ensure that the health, safety and welfare at work of all its employees and visitors, so far as is reasonably practicable. Specifically, an employer must provide:

– Safe plant and systems of work

– Safe use, handling, storage and transportation of articles and substances

– Necessary information, instruction, training and supervision

– A safe place of working include safe access and egress

– Safe working environment and adequate welfare facilities

The MHSWR requires employers to carry out risk assessments of their premises and activities to identify sources of potential harm. Having identified such sources or hazards, the employer must assess the likelihood of harm occurring and then implement and maintain effective control measures.

Employee responsibilities

The HASAWA requires employees to take reasonable care for their own health and safety and that of others. Employees are also required to co-operate with their employer’s health and safety policies and procedures and must not deliberately misuse any item or

equipment provided for health and safety purposes. Under the MHSWR, employees also have a duty to report any shortcomings or concerns about health, safety and welfare.

The Accident Book

If you have an accident you must complete the Accident Book (or ask someone who witnessed the accident to complete it for you) as soon as practicable. The Accident Book is with the Office Manager. At CBRE Investment Management, all near misses are regarded as potential accidents and therefore, must be recorded in the Accident Book and a full investigation will be undertaken.

Please see the definitions for an accident and a near miss below:

An accident is an unplanned, uncontrolled event, which HAS led to:

– Injury to persons

– Damage to plant

– Some other loss to the Company

A Near Miss is an unplanned, uncontrolled event, which COULD HAVE led to:

– Injury to persons

– Damage to plant

– Some other loss to the Company

First aid & first aid facilities

All CBRE Investment Management’ First Aiders hold either a full “First Aid at Work” certificate and have attended a three-day course, or a one-day basic course and will be designated as an “Appointed Person”. Full First Aiders are paid an allowance of £120 (gross) per annum, payable on a monthly basis via Payroll. “Appointed Persons” do not receive any payment.

In the event of an accident/injury, please notify a First Aider or ask someone to contact one for you. A list of qualified First Aiders is held on UNITE, and is on the notice board in the town square.

All First Aiders have a fully equipped First Aid box.

Fire

Please familiarise yourself with your office’s fire procedures. Please ensure that you identify the following on your floor:

– The area your workstation is in

– Your nearest fire call point button

– Your area’s nearest fire exit route

– Who the Fire Marshalls are on your floor and where they sit

– Ask your manager to give you a tour of your floor pointing out the Fire Exit Stairwells, the location of the call point buttons and the location of the CBRE IM Fire Point Assembly

Your workstation Chair

The chair provided will meet ergonomic stipulations and will be fully adjustable. Employees should be able to adjust their chairs as follows:

– Seat height

– Seat length

– Angle of back of chair

– Height of back of chair

– Option of settings for chair back e.g. free-flow or fixed

– If arms are fitted, these should be height adjustable

Footrest

You should be able to able to rest your feet on the floor. If you can’t, please contact the Facilities who will either source a footrest from stock or order one for you.

Desk

In the interests of health and safety, your desk should be as free from clutter as possible. CBRE operates a clear-desk policy and therefore, we would request that you clear your desk of papers and files etc. before you leave each evening. This will ensure that the cleaners can adequately clean your desk.

PC/Telephone

The PC monitor provided has tilt and swivel functions. It also has full contrast and brightness controls. If you have any problems with your PC or telephone please contact the IT Help Desk.

Eye test

Any employee who consistently uses a VDU for more than two hours per day is entitled to have an eye examination every year or as recommended by their optician. Eye test vouchers are available via the online portal found on the intranet and can be used at an optician locally.

Reasonable adjustments

Employees are obliged to advise CBRE IM if they have a specific medical condition or disability so that the Company may assess the risks to health and provide any

reasonable adjustments, which may be required in order to ensure employee welfare. For confidentiality, please advise the UK Health & Safety Manager, who will carry out a one to one assessment.

Please also refer to the DSE guidance which can be found on UNITE. It is envisaged that with the aid of the DSE policy employees will be able to carry out initial DSE self-risk assessments of their workstations. Should discomfort persist or concerns remain, employees have a duty to raise these with their manager and request an assessment to be carried out by the Office Manager.

Health & safety training

All new employees should attend the Company induction where health & safety information will be provided. Additional work-related health and safety training may be required, eg Manual Handling training (for those employees whose work involves regular lifting, lowering, pushing, pulling and sliding of loads), Risk Assessment Awareness (for those employees who carry out surveying within the Building Consultancy department) etc. Any additional training will be conducted on an ‘as-needs’ basis. All Health and Safety training can be arranged through the People department.

Environmental policy & procedure

CBRE Investment Management is committed to carrying out its operations in such a way that any environmental impact is kept to a minimum.

Every member of staff has a responsibility to carry out their day to day activities in an environmentally responsible manner.

CBRE IM has an environmental champion who will be able to assist you further but please be aware of the following:

There are different waste collection bins for different wastes including recycling, general waste, printer cartridges, food and confidential waste.

– Please ensure that your laptop is turned off completely at the end of each day and that your monitor is not left in the standby mode

– Ensure that you only print off documents if absolutely necessary and that your laptop is set to black and white double sided printing

– Take advantage of video conferencing facilities which are available in our offices rather than travelling

– Where possible use public transport to attend meetings

Finally, if you have any suggestions that may be of an environmental benefit for your office, or the wider Company, please forward these to the Office Manager.

Security alert

In the event of a bomb alert:

– Await instructions from your Fire/Security Marshall

– Always follow the lead of your Fire/Security Marshall

Smoking

The Company operates a No Smoking policy throughout all offices (this includes ecigarettes). This applies regardless of the time of day. Smoking will only be permitted outside the buildings, but not outside the front entrances.

Smokers must ensure that cigarette ends are not left around the outside of our offices. Managers interviewing for new staff should clearly state the policy.

Disciplinary action will be taken against anyone not complying with these restrictions.

Safety of employees visiting unoccupied buildings/sites

All employees must be aware of the Lone and Field working procedure which is available on the CBRE Health & Safety intranet page. All employees are asked to review the full policy on joining the Company.

When you attend vacant sites alone you must contact your nominated departmental contact of your location, with a contact number, the approximate time you will spend on site and to let your departmental contact know when you are leaving the site.

This should be repeated for every site that you visit on your own that is vacant.

Failure to follow this may result in disciplinary action.

Should you fail to call in, then your departmental contact will then try to contact you. If they fail to contact you, then they will escalate an emergency procedure which may involve calling the emergency services.

A model risk assessment has been produced for surveying, make yourself familiar with this. Where you are undertaking specific high risk activities such as roof work, a separate risk assessment must be done before you start work.

Whether the site is occupied or not, as much information on the site should be obtained from the Client, landlord etc. before attending site and your whereabouts should be known to your department including your location and contact number/name of client. This should be easily accessible by someone in your department (e.g. electronic calendars).

Attack alarms are available on request from the Health & Safety Team. It is your responsibility to phone in when attending and leaving a site.

Alphabetical Index

Additional leave

Appraisals.............................................

Auto enrolment scheme.........................

Benefits for part time staff

Birth of baby/adoption of child.............

Car & mobile phones............................

CBRE Investment Management

house rules.............................................

Charity/volunteering work....................

Code of conduct and compliance rules

Company cars.........................................

Compassionate leave

Compensation & benefits

Compliance with company policies and procedures..........................

Confidentiality

Continuing Professional Development (CPD)..............................

Data Privacy and Protection

Disability code of good practice...........

Disciplinary code..................................

Dress code

Electronic communication policy.....

Employee assistance programme.........

Environmental policy & procedure

Equal opportunities.........................

Equal opportunities officer...................

Equal opportunities policy

Expenses guidelines.............................

Family policies.................................

Fire

First aid & first aid facilities..................

Flexible working...................................

General administration

Gifts & Hospitality...................................

Government

Agencies………………………………………… ……….…40

Grievance procedure

Health & safety...............................

Health & safety – Employer responsibilities

Health & safety training.......................

Holiday entitlement................................

Holiday purchase scheme

Holidays.............................................

Incentive pay schemes...........................

Internal vacancies

Intranet/Unite.......................................

Jury service...........................................

Learning & development

Life insurance.........................................

Long service awards.............................

Loss of property / contents

insurance..............................................

Marriage/Civil partnership....................

Maximum weekly working time

Medical screening...................................

Minimum periods of weekly and daily rest and minimum breaks whilst working

Monitoring............................................

Moving house.......................................

Notification of changes in information

Outside interests & employment............

Parental leave/time off for dependants

Pension................................................

Pension scheme......................................

Permanent health insurance

Personal account dealing.......................

Policies & procedures......................

Policy on discrimination, harassment and victimisation

Privacy.............................................

Private medical insurance......................

Promotion

Recruitment..........................................

Recruitment bonus (refer a friend)

Regulatory obligations............................

Reserve Armed Forces..........................

Safety of employees visiting unoccupied buildings/sites

Salary.....................................................

Scope of equal opportunities policy....................................................

Season ticket loans

Security................................................

Security alert........................................

Sickness

Smoking...............................................

Sports and social..................................

Student loans

Technology queries..............................

Termination of employment............

Terms and conditions of employment.........................................

The complaints procedure....................

Training, career development & promotion

Training, career development and promotion......................................

Travel policy & Insurance

Working time directive.........................

Your obligations....................................

Your personal data

Your workstation.............................