CBRE Internal Policies

Question 1

What is CBRE’s DE&I Policy?

Answer 1

• RISE Values (Respect, Integrity, Service, Excellence)
• Aim to create a “borderless culture”
• Culture office which oversees the policy & helps to develop senior leadership talent (led by Banke Odunaike)
• Employee Resource Groups (LGBTQ+, Military / veternan, working parents, Rising professionals, woman’s network, faith networks)

Question 2

What is CBRE’s AML Check?

Answer 2

• Obtain understanding of beneficial owners
• Ask our compliance team to put this entity / personnel through a software called World Check as they are the only ones who have the license.
• In regards to PEP & High Risk individuals, Geraldine Mash keys a risk register
• We also use D&B Reports
• If someone is on the sanctions list we cannot work with them unless they have a license from HMRC. If we do work with someone on the sanctions list who does not have a license there is as an auto fine of £1m

Question 3

What is your Firms policies on Gifts / Bribes?

Answer 3

• Zero tolerance on bribes
  Register any gift you receive in the gift register and inform compliance
• Any gift over £100 you need to inform the compliance team and check if you can accept / go to the event
• Cash Gift - Never accepted
• Vouchers - Raffle off
• CBRE have started a new initiative that was prompted by seasonal gifted
• When applicable, the gift will be stamped with “compliance team aware” prior to getting to the recipient.

– CBRE is an American company, therefore the firm is also subject to US legislation such as Foreign Corruption Policy Act (FCPA)

Question 4

How does your firm undertake COI?

Answer 4

• Detail / Confirm client entity and address
• Run details through internal system called CBRE - CIS” which generates an excel document with potential conflicts
• Analyse the sheet and react as required.

Question 5

What is CBRE’s PII cover?

Answer 5

• Standard base of £5 million per claim. However we can get up to £100 million
• Valuation terms dictate a base cover of £20 million

Question 6

What is CBRE’s Complaints Handling Procedure?

Answer 6

• Can be viewed and downloaded both on CBRE public website (as per RICS requirement) and the internal employee intranet page
• This is managed by our Compliance Director, Geraldine Mash.
• In the event clients would like to make a formal complaint, they are asked firstly to do so to the Director leading the instruction.
• Once a complaint has been received, CBRE will contact the client in writing within 5 working days to inform you of who will be responsible for investigating your complaint and how this will be conducted.
• Within 20 working days of written confirmation of the complaint, the person investigating the complaint will write to inform the client of the outcome and to let them know what actions have been, or will be, taken.
• If the complaint takes longer to investigate, CBRE will write to inform the client of our progress.
• ADR - If the complaint has not been resolved to the client’s satisfaction, CBRE will agree that the matter may be referred to one of the following organisations: The Centre for Effective Dispute Resolution – Mediation for commercial.

Question 7

What are CBRE’s goals?

Answer 7

• Focus on high growth areas in the business, e.g. industrial and logistics, Sustainability and Renewable teams. Become an even stronger business and keep servicing clients. Want to increase market share and be the clear market leader. Hire and retain the best talent.
• Long term – climate change and diversity are key priorities in the long term. Net zero carbon by 2040.

Question 8

CBRE’s Sustainability Policy

Answer 8

• Net Zero Carbon by 2040.
• Fully dedicated Environmental Consultancy / Sustainability team.

Question 9

What is CBRE’s GDPR Policy?

Answer 9

• 6 month rule (if we have not heard from a contact in our database for a period of over 6 months we archive the contact.

Question 10

CBRE’s Health & Safety Policy?

Answer 10

• This is required for companies with more than 5 people.

Under the H&S Policy we need to:

• Know Fire procedures
• Sign in/out of the office
• 2 people qualified in first aid (Andrew Michel and Myself)
• RAMS – on inspection and in the office
• Injury reporting/Recording if 7 days incapacitated (HSE within 15 days)
• Manual Handling/Display Screen/PPE/Use of equipment/Workplace/H&S Management
• Lisa Pacitti in charge of the H&S documentation in the Aberdeen office.