LEGAL

POLICY 6.18 ANTI-CORRUPTION

EFFECTIVE DATE: February 1, 2006

REVISED: July 1, 2011; August 1, 2014; March 1, 2017

I. POLICY

CBRE Group, Inc. and its worldwide subsidiaries (collectively, “CBRE”) have adopted the
following Policy with respect to all of their global commercial transactions. Oversight of
this Policy and CBRE’s internal controls regarding bribery, including the authority to
report matters directly to independent monitoring bodies such as Global Assurance &
Advisory, the Board of Directors and its committees and/or external law enforcement, is
the duty of the Chief Ethics and Compliance Officer and the Chief Accounting Officer,
who shall have an adequate level of autonomy from management and shall be given
sufficient resources and authority to carry out this responsibility.

II. SCOPE

This Policy applies to CBRE and all CBRE Personnel and should be read in conjunction
with the Standards of Business Conduct (“SOBC”). Responsibility for compliance with
this Policy and the related internal controls, ethics and compliance programs or measures
is the duty of individuals at every level of CBRE. CBRE will endeavor in good faith to use
its influence to the extent reasonable under the circumstances to require entities not
controlled by CBRE but which operate on behalf of CBRE and/or under the CBRE brand
(e.g., Representatives) to adopt and implement policies and internal controls of their own
that minimize the risk of violation of the anti-corruption laws relating to CBRE’s business.

III. DEFINITIONS

A. Authorized Approver. A member of the management of a country operation,

global region or business unit who is designated by the most senior manager
within such operation, region or business unit or by the Regional CFO or COO as
having the authority to approve the applicable action covered by this Policy. The
designation of any Authorized Approver shall be subject to approval by the
applicable Regional Compliance Officer, and the Regional Compliance Officer or
its designee Country Compliance Officer shall be responsible for providing
adequate training to the Authorized Approver of such person’s responsibilities
under this provision.

B. Bribe. Any payment, gift, promise or offer of money or anything of value1 ,

whether directly or indirectly through intermediaries, to any person or entity for
the purpose of (a) improperly influencing any act or inaction, or decision or non-
decision of the recipient in his or her official capacity, (b) inducing the recipient to
act or refrain from acting in relation to the performance of their duties, (c)
securing improper advantage, (d) obtaining or retaining business, (e) inducing
the recipient to use influence with a third party (including a Government Entity) to
affect or influence any act or inaction, or decision or non-decision of such third

1“Anything of value” includes, but is not limited to, cash, cash equivalents, services, gifts, travel
expenses, entertainment, offers of employment or internships, meals, vouchers, event
sponsorships, pledges or donations.

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POLICY 6.18 ANTI-CORRUPTION

EFFECTIVE DATE: February 1, 2006

REVISED: July 1, 2011; August 1, 2014; March 1, 2017

party, or (f) “rewarding” a recipient after the fact for affecting or influencing any
act or inaction, or decision or non-decision of a third party.

C. CBRE Personnel. All CBRE officers, directors, employees and any individual or
entity acting for or on behalf of CBRE, operating in any part of the world. CBRE
Personnel shall include temporary or seconded personnel, whether or not
employees, who are also employees of third party agencies.

D. Facilitating or Grease Payment. A small payment made to a Government Entity

in order to encourage or reward it before, during or after the fact to expedite a
non-discretionary, routine governmental task that it is otherwise required to
undertake, such as processing government paperwork, while providing routine
government services. Examples of Facilitating or Grease Payments include
small fees to receive police protection, mail pick-up, a stamp of an entry visa, or
to have a telephone line installed or an application processed. Routine
governmental action does not include (1) a decision by a foreign official to award
business to, or to continue business with, a company, or (2) an action or inaction,
or decision or non-decision to which CBRE is not legally entitled.

E. Government Entity. A government, government body or department,

government employee, representative or official, public official, political
candidate, political party, party official, public international organization (e.g.,
United Nations or World Bank), a state owned entity (SOE) and every employee
of a SOE regardless of rank or title and regardless of how local law may
characterize the employee. The term Government Entity should be interpreted
broadly and may also include individuals in unpaid or honorary government
positions, including committees, panels, commissions or other advisory positions.

F. Intermediary. A person that contacts or interacts with a Government Entity on

behalf of a third party, including a client (e.g., obtaining permits, licenses,
occupancy certificates, government data, planning approval, building approval,
building completion certificates, fire and safety certificates etc.).

G. Kickback. A particular form of Bribe which takes place when a person entrusted
by an employer or Government Entity has responsibility for the granting of a
benefit (e.g., awarding a contract) and does so in a way that secures for his or
herself a return (kickback) of some of the value or benefit of that transaction
without the authorization of his or her employer or Government Entity.

H. Policy. The 6.18 Anti-Corruption Policy, as amended from time to time.

I. Regional Compliance Officer. The Regional Compliance Officer for a global

region or the most senior compliance officer responsible for a business unit (e.g.,
the Chief Compliance Officer for CBRE Global Investors).

J. Representative. Any person or entity acting on CBRE’s behalf for the purpose of
developing or securing new business opportunities, retaining existing business
opportunities or assisting CBRE or a client to obtain a license or approval from a
Government Entity. Representatives may include finders, introducers, certain

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POLICY 6.18 ANTI-CORRUPTION

EFFECTIVE DATE: February 1, 2006

REVISED: July 1, 2011; August 1, 2014; March 1, 2017

consultants, agents, co-brokers, referring brokers, joint venture partners and

CBRE affiliates or licensees.

K. SOE. State-owned or state controlled commercial enterprises, which are

companies over which a Government Entity exercises substantial control (even if
not wholly-owned) and are therefore deemed an “instrumentality” of the
Government Entity.

III. PROVISIONS AND CONDITIONS

A. Compliance with Laws. Neither CBRE nor any CBRE Personnel may, directly
or indirectly, break or seek to evade the laws or regulations of any country in or
through which it does or seeks to do business. That an illegal act is “customary
business practice” or “local practice” in any geography is not sufficient
justification for violation of this provision and therefore any employee in violation
of this Policy will be subject to disciplinary actions, up to and including
termination.

B. Anti-Corruption Provisions.

1. Bribes and Kickbacks -- Neither CBRE nor any CBRE Personnel may,
directly or indirectly, authorize, offer, provide, solicit or receive a Bribe or
Kickback for its own account or as an Intermediary or agent of a CBRE client
and all offers of, or solicitations or demands for, Bribes and/or Kickbacks
must be expressly rejected. This provision prohibits Bribes and Kickbacks to
Government Entities, commercial entities and individuals. CBRE will take
reasonable steps to prevent Representatives acting on its behalf from
violating this provision.

2. CBRE Acting as an Intermediary with a Government Entity -- If CBRE is

expected by a client to act on its behalf as an Intermediary with a
Government Entity, the contract with the client should be clear as to the
scope of services, and any payments or subcontracts undertaken in
furtherance of the assignment shall be approved by an Authorized Approver.
CBRE and CBRE Personnel shall under no circumstances act as a conduit to
pass-through a Bribe, Kickback or Facilitating or Grease payment either on
its own or via a third party on behalf of a client. Any CBRE Personnel found
to have been directly, indirectly or complicit in engaging in such prohibited
conduct shall be subject to disciplinary actions, up to and including
termination.

3. Client Transactions with Government Entities (including SOEs) -- Each

country operation, region and business unit shall make best efforts to identify
all client transactions to which a Government Entity (including an SOE) is a
party and to submit such transactions to an Authorized Approver for review
for compliance with this Policy.

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POLICY 6.18 ANTI-CORRUPTION

EFFECTIVE DATE: February 1, 2006

REVISED: July 1, 2011; August 1, 2014; March 1, 2017

4. Facilitating or Grease Payments -- CBRE prohibits Facilitating or Grease

Payments, regardless of whether such payments are permitted by the
government within the jurisdiction where such payment is proposed. Such
payments are prohibited under the laws of the great majority of the countries
where we operate.

5. Charitable and Political Contributions -- CBRE prohibits any charitable or

political contribution by or on behalf of CBRE or any CBRE Personnel to any
entity, including at the request or suggestion of a Government Entity (or a
family member of a Government Entity employee), in order to gain an
improper business advantage. Each country, region and business unit shall
adopt a written policy, approved by the Regional Compliance Officer,
governing charitable and political contributions. Neither CBRE nor any
CBRE Personnel may authorize, make or reimburse any charitable or
political contribution relating to CBRE’s business unless it (1) is approved by
an Authorized Approver in compliance with the applicable written policy, (2)
is legal in the country in which incurred, and (3) is properly recorded in the
books and records of CBRE.

6. Travel, Meals, Entertainment, Client Events and Gifts -- This Policy does
not prohibit reasonable expenditures for travel, meals, entertainment, client
events and gifts and similar or related expenses of a Government Entity with
a bona fide and documented business purpose. Each country operation,
region and business unit shall adopt a written policy, approved by the
Regional Compliance Officer, governing expenditures for travel, meals, gifts
and entertainment. Such expenditures made to or on behalf of a
Government Entity are prohibited unless they are (1) approved by an
Authorized Approver in compliance with the applicable written policy, (2)
legal in the country in which incurred, and (3) properly recorded in the books
and records of CBRE. In addition, for any CBRE function for which any travel
or lodging is paid by CBRE, the attendance of any Government Entities must
be approved by an Authorized Approver in advance. With respect to
business travel with any client or third party, CBRE will not provide any
advances, reimbursements, or per diem or “walking around money.”

7. Cash Advances -- Cash advances to CBRE Personnel must be approved by

an Authorized Approver. The Authorized Approver for any cash advances to
the most senior manager in any region, country operation or business unit
shall be the CFO of the Region or his/her designee.

8. Hiring Employees or Family Members of Clients -- From time to time

CBRE may offer internships, employment or similar positions to employees
or family members of clients. However, all hiring decisions should be made
on the merits, and be based on the qualifications of the candidate for the
position, and making any such offer in order to gain an improper business
advantage is strictly prohibited. In addition, CBRE will not offer internships,
employment or similar positions to a Government Entity or a family member
of a Government Entity employee without advance approval of an Authorized
Approver.

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POLICY 6.18 ANTI-CORRUPTION

EFFECTIVE DATE: February 1, 2006

REVISED: July 1, 2011; August 1, 2014; March 1, 2017

9. Sponsors of Visa Applications -- CBRE will not sponsor any visa

application for any party who is not a CBRE employee (e.g., an employee of
a client) without a valid and specific business reason. Sponsorship of visa
applications in order to gain an improper business advantage is strictly
prohibited. Visa sponsorships for family members or employees of
Government Entities require the advance approval of an Authorized
Approver.

10. All Payments/Transactions Must be Approved -- Even if the exact type of

payment or transaction is not specifically described here, any payments or
offers of anything of value for any purposes to a Government Entity, must be
approved in writing by an Authorized Approver and recorded accurately in
the Company’s books and records.

C. Books, Records and Due Diligence

1. Company Accounts -- CBRE shall maintain complete and accurate financial

records, ensuring that all transactions are properly, accurately and fairly
recorded in its books and records. The book entries must be clear and
accurate. Obscuring or euphemistic language must be avoided. The
obligations above shall apply to client financial records and accounts (e.g.,
property-level trust accounts) managed by CBRE.

2. Relationships with Representatives

a. Selecting and Vetting Representatives -- To minimize the risk that
CBRE will be held responsible for unauthorized actions of
Representatives that violate the anti-corruption laws, before engaging
any Representative CBRE will satisfy itself of the potential
Representative’s relevant expertise and good professional standing,
that the Representative is not a Government Official, and is not a
related party of or directly or indirectly employed by an existing or
prospective client. It is a violation of this Policy to engage a
Representative on behalf of a client to execute a coordinated scheme
to divide a payoff or mutual benefit. In addition, with respect to
Representatives that are likely to interact with a Government Entity on
CBRE’s behalf, CBRE will engage in and document due diligence
regarding the Representative’s background. This due diligence shall
be designed to reasonably gauge the level and nature of anti-
corruption risk posed by the Representative, as determined by the
Regional Compliance Officer. Minimum due diligence standards
(including checklists) will be approved in advance by the Chief Ethics
and Compliance Officer.
b. Contracts with Representatives -- CBRE has an obligation to be
knowledgeable about the activities undertaken by Representatives on
CBRE’s behalf and shall have written contracts with these
Representatives. Contracts with Representatives that are reasonably

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POLICY 6.18 ANTI-CORRUPTION

EFFECTIVE DATE: February 1, 2006

REVISED: July 1, 2011; August 1, 2014; March 1, 2017

likely to interact with a Government Entity are to be reviewed and

signed by an Authorized Approver, and shall contain a set of standard
representations, warranties and covenants in a form approved by the
Regional Compliance Officer.
c. Follow-up on Representatives -- Once the contractual relationship
commences with a Representative, CBRE will monitor the
Representative’s performance to satisfy itself that it is in accordance
with the contract. This may include communications, certifications,
periodic performance reviews, and audits. CBRE should encourage
Representatives to document their days of work, research and
analysis, project staffing levels, travel and other expenses incurred on
CBRE projects. Documentation of these procedures and other
information collected during the contractual relationship should be
retained for not less than five years after the relationship has
concluded.
d. Recommending Third Parties to Clients -- No CBRE Personnel
shall make a referral or recommendation to a CBRE client of a third
party if the CBRE Personnel knows or should know that such third
party would likely pay a Bribe or Kickback on behalf of the Client.
e. Red Flags in Relationships with Representatives -- Standard
procedures and contract terms, however, are no substitute for our
employees’ personal business judgment. There are certain "red
flags" that indicate a relationship with a Representative may cause the
Company undue risk under the anti-corruption laws. (See Exhibit A
for examples of “red flags.”) If any red flags are identified, they must
be further investigated and resolved and any relationship with such
Representative must be approved in writing by the Regional
Compliance Officer in addition to the Authorized Approver.

D. M&A, Affiliates and Other Corporate Transactions -- Prior to entering into any
mergers, acquisitions, equity investments, affiliate agreements, joint ventures or
similar transactions, CBRE must complete due diligence on the counterparty
designed to reasonably determine the level and nature of anti-corruption risk
posed by the transaction. The form and manner of the due diligence will be
determined by the Chief Ethics and Compliance Officer based on the proposed
nature, structure, scope, size and location of the transaction.

E. Auditing and Monitoring – CBRE shall periodically audit and monitor

compliance with this Policy. CBRE Personnel and Representatives may be
required to execute certifications of policy compliance.

F. Risk Assessment – CBRE shall conduct periodic risk assessments to assess

changing conditions in each country of operations, line of business and ongoing
relationships with third parties, affiliates, and the like.

G. Hiring – To mitigate the risk that authority will be vested in a person not
trustworthy to act responsibly, CBRE should conduct reference and/or

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POLICY 6.18 ANTI-CORRUPTION

EFFECTIVE DATE: February 1, 2006

REVISED: July 1, 2011; August 1, 2014; March 1, 2017

background checks, in a manner determined by the Regional Compliance

Officer, on all candidates for management positions (including property
managers) or any position designated as an Authorized Approver, and certain
other positions as may be determined by the Regional Compliance Officer.

H. Reporting Violations – CBRE Personnel who become aware of a possible

violation of this Policy or the anti-corruption laws or who are subjected to any
form of extortion or are asked to participate in a bribery or kickback scheme must
report it through one or more of the avenues for reporting misconduct set forth in
the Standards of Business Conduct. This includes the Company’s toll-free Ethics
Helpline, which may also be accessed by clients or other business partners. Any
person contacted regarding an incident or violation under this Policy must
promptly report such contact to the Chief Ethics and Compliance Officer.

I. Retaliation is Not Tolerated – CBRE prohibits retaliation against any person

who in good faith raises questions or concerns, reports a violation or assists in an
investigation under this Policy. No CBRE Personnel will suffer demotion, penalty
or other adverse employment action as a result of not paying or agreeing to pay
Bribes or Kickbacks, even when CBRE may lose business opportunities as a
result. Please see Policy 4.2.8 – Non-Retaliation for more information.

J. No Undue Pressure – No manager or supervisor may ask, pressure, require or

encourage any CBRE Personnel to violate this Policy. Following a superior’s
orders will not excuse any such violation.

K. Investigations – If a report regarding violation of this Policy is received, it will be

investigated and documented in accordance with CBRE’s approved investigation
procedures, and appropriate action based on the findings of such investigation
will be taken. Please see Policy 4.2.9 – Investigations of Legal and Ethical
Misconduct for more information. CBRE Personnel are expected to provide full
cooperation and truthful answers in an investigation and failure to do so will result
in disciplinary actions, up to and including termination.

L. Disciplinary Action – Any employee who violates the law, this Policy or any
related policy or procedure will be subject to appropriate disciplinary action, up to
and including termination. In addition, CBRE may choose or be required to
report violations to law enforcement or other regulatory agencies, and CBRE
Personnel should be aware that individuals are held personally accountable
under the anticorruption laws. In determining the appropriate disciplinary action,
CBRE will take into consideration the circumstances under which an improper
payment was made (e.g., whether there was a good faith belief that the CBRE
Personnel’s personal safety was threatened or under the threat of physical
violence or incarceration, whereby such payment made under a genuine threat is
promptly reported to CBRE) consistent with the provisions of this Policy.

M. Communication and Training – CBRE will periodically issue written

communications to employees in order to promote awareness of and
engagement with, as well as demonstrate top-level commitment to, this Policy.

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POLICY 6.18 ANTI-CORRUPTION

EFFECTIVE DATE: February 1, 2006

REVISED: July 1, 2011; August 1, 2014; March 1, 2017

An appropriate level of anti-corruption training will be provided to employees and

Representatives based on a risk assessment of needs relative to job function.

N. Further Guidance – If any CBRE Personnel has any questions or needs urgent
advice about this Policy, they should contact our Chief Ethics and Compliance
Officer, the applicable Regional Compliance Officer, any lawyer in the Legal
Department or designated compliance liaisons in certain country operations or
business lines. In addition, the CBRE Ethics Helpline is available at any time to
offer advice or answers to questions regarding this Policy, including on an
anonymous basis.

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POLICY 6.18 ANTI-CORRUPTION

EFFECTIVE DATE: February 1, 2006

REVISED: July 1, 2011; August 1, 2014; March 1, 2017

EXHIBIT A

Red Flags

Over the years, enforcement agencies of governments have identified a number of “red
flags” that may be indicative of an increased risk or a potential violation of anti-corruption
laws (note, this list is not intended to be exhaustive):

General Red Flags:

• A Representative had an “improper payment” audit in the past five years.

• Certain countries have widespread corruption and/or a history of violations.

• Certain countries are in the news for the prevalence of payoffs, Bribes, or Kickbacks.

• A Representative is trying to develop sales in an industry with a history of problems

like the defense, aircraft pricing, oil, and construction industries.

Transaction-Specific Red Flags:

• A Representative refuses to certify that he will abide by CBRE’s Anti-Corruption

Policy.

• Close family or business ties of a Representative with a government official exist.

• A Representative has a bad business reputation. (It is important to document the

good reputation and experience of the Representative engaged.)

• The Representative requires that his identity not be disclosed.

• The Representative lacks the facilities and staff to perform the required services.

• The Representative is inexperienced or new to the business.

• Odd requests that reasonably arouse suspicion are made by a Representative, for
example, a request to backdate invoices.

Payment Request Red Flags:

• A Representative requests a commission that is substantially above the going rate for
similar work in a particular country. Permissible commissions vary from country to
country and from case to case.

• A Representative makes requests for payment through artificial mechanisms, such as

a numbered bank account in a third country.

• A Representative suggests over-invoicing or requests a check for more than the actual
amount of expenses.

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POLICY 6.18 ANTI-CORRUPTION

EFFECTIVE DATE: February 1, 2006

REVISED: July 1, 2011; August 1, 2014; March 1, 2017

• A Representative suggests that checks be made out to “cash” or “bearer,” that

payments be made in cash, or that bills be paid in some other anonymous form.

• Payment in a third country may be legitimate but can suggest a plan to divide the
commission outside of government scrutiny.

• If a Representative requests an unusually large credit line for a customer, you should
be suspicious, especially if the customer is new.

• Requests for unusual bonuses or extraordinary payments also are questionable.

• A Representative requests an unorthodox or substantial upfront payment.

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