Ethics, Compliance and Corporate Social Responsibility in Supply Chain. Supply Chain Management and Procurement Legal & Compliance

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1 Ethics, Compliance and Corporate Social Responsibility in Supply Chain Supply Chain Management and Procurement Legal & Compliance

2 Integrity is doing the right thing, even if nobody is watching. 2

3 JLL s Ethical Commitment JLL is in Ethisphere Institute s World s Most Ethical Companies list for 11 consecutive years Ethisphere recognizes companies commitment to ethical business practices linked to performance and profitability The list is comprised of 135 companies in 23 countries and 57 industries 2017 Jones Lang LaSalle IP, Inc. All rights reserved. 3

4 Achieving Ambitions the JLL Way Teamwork The JLL Way Excellence Ethics 2017 Jones Lang LaSalle IP, Inc. All rights reserved. 4

5 Ethics and Compliance Issues Add to Cost of Business Bribery Fraud Money Laundering Conflict of Interest Data Breach Modern Slavery Inappropriate Behaviour Health & Safety Violation Misuse of client property Lawsuits Regulatory Action Investigation Costs Penalties/Fines Contractual Liabilities Data Loss Loss of Business Terminations Reputational Damage 2017 Jones Lang LaSalle IP, Inc. All rights reserved. 5

6 Business Ethics and Supply Chain We expect our business partners to share our commitment to ethical conduct in business We are responsible for your conduct under client contracts Say Regulators also hold us accountable for ethical conduct in our supply chain Finally, your business practices impact our reputation and the JLL Brand which is one of our most important assets Believe Ethics Do 2017 Jones Lang LaSalle IP, Inc. All rights reserved. 6

7 Your Role as Business Partner Regulatory Compliance Compliance with laws and regulations on bribery and corruption, competition, environment, personal data, labor and employment, workplace safety, maintenance of accurate books and records and other matters Compliance with JLL s Vendor Code of Conduct In addition to regulatory compliance, JLL s expectations with respect to ethical business practices, clearance of conflicts of interest, commitment to health, safety, environment and ethical labor practices, management accountability, and ethics awareness and training for employees Compliance with Client s code of conduct Policies and processes mandated by JLL s clients which may be similar to JLL s Vendor Code of Conduct but with stricter requirements 2017 Jones Lang LaSalle IP, Inc. All rights reserved. 7

8 Fair Business Practices Bribery and Corruption Bribery or corruption is not only unethical but also illegal Do not offer or give any illegal, improper or questionable payment, benefit, service or anything else of value to any government or public official, or anyone at JLL or any third party, for getting business or any business advantage. Our policy prohibits even small facilitation payments to government officials even though they may be considered normal practice in some countries. Maintain accurate books and records that reflect the true nature of the transactions. Do not alter or falsify or backdate records. There must be full transparency regarding date, recipients and purpose of payments. JLL is a public company listed on the New York Stock Exchange with operations in over 80 countries Compliance by JLL (and the suppliers who act on our behalf) with the U.S. Foreign Corrupt Practices Act (FCPA), the U.K. Bribery Act, and the anti-corruption laws of the countries in which we operate is mandatory. Violation can result in civil enforcement suits as well as criminal prosecution by the relevant regulatory body Jones Lang LaSalle IP, Inc. All rights reserved. 8

9 Fair Business Practices Fraudulent Behavior Do not take advantage of customers or business associates through manipulation, concealment, abuse of privileged information, misrepresentation, fraudulent behavior or any other unfair-dealing practice. Comply with applicable antitrust and competition laws (including those relating to price discrimination, price fixing, and restraint of trade and monopolies). Comply with all applicable anti-money laundering laws, and never knowingly participate in a scheme to launder money, under-report the size of a transaction, or wrongfully avoid tax liability Do not use JLL or client information you come across in the course of providing services to JLL/clients for any personal benefit or gain (including purchasing or selling stock) Companies profit from a reputation of acting with honesty and integrity 2017 Jones Lang LaSalle IP, Inc. All rights reserved. 9

10 Conflict of Interest You may have multiple interests that conflict with each other or JLL employees making decisions for the firm may have personal interests. If not addressed, such conflicts can result in bribery, self-dealing or nepotism which undermine one s duty to stakeholders and clients. Business decisions and actions should always be driven by objectivity, transparency and integrity rather than personal gain. Conflicts can be cleared but require Transparency and Integrity JLL employees must not use their position for any improper benefit If a JLL employee or family member has any interest or influence in your company (as director, officer, shareholder, advisor etc.), disclose that relationship so that we can ensure that JLL s interests rather than that relationship drives decisions Disclose all other dealings (gifts/entertainment, loans, financial interests) by your company or employees with JLL employees or their family members Conflicts must be cleared if you wish to be engaged by, or continue providing services to, JLL 2017 Jones Lang LaSalle IP, Inc. All rights reserved. 10

11 Gifts and Entertainment Grow your business through fair means and not through gifts, entertainment, loans, favors or anything else that influences, or might influence, business decisions. JLL purchases goods and services on the merits of price, quality, performance and suitability. JLL employees cannot as a general rule accept gifts or entertainment from suppliers as they create a conflict of interest and may be viewed as bribery. The only exception is a token of appreciation that is otherwise appropriate in the circumstances. Gift or entertainment that is an acceptable token of appreciation: has a nominal value (between US$ depending on the country) and is not given in the expectation of any favor; and is not connected to a procurement decision (whether supplier engagement or assessment or monitoring); and is otherwise appropriate and reflects good judgment 2017 Jones Lang LaSalle IP, Inc. All rights reserved. 11

12 JLL and Client Systems JLL Vendor Information Security Requirements (based on ISO framework) establish role-based controls for suppliers accessing JLL/client systems or providing technology services. Comply with JLL s requirements on controls such as: security management, access management, asset protection, firewalls, cryptography, business continuity, network security, secure development, andsystem monitoring. Protect and use technology and systems provided by JLL/clients responsibly and only for authorized business purposes. Do not misuse JLL/client resources and facilities, whether physical or digital. Remember, all data stored or transmitted on JLL or client equipment is considered private and is the property of JLL or such client. Weak controls enable unauthorized access and cyber-attacks on systems leading to data leak or loss, ransomware, phishing and other theft or damage to systems and data. Any act compromising the security and integrity of systems or property will have significant implications for JLL and clients Jones Lang LaSalle IP, Inc. All rights reserved. 12

13 Information Security and Data Privacy Information on JLL s and clients operations, sites, customer lists, financial affairs, products and services, business strategy and such other information is proprietary and confidential You have a duty to protect JLL/clients confidential information against unauthorized access or disclosure, whether intentional or inadvertent Information breach can have significant consequences including: Regulatory action under laws/regulations governing data security and integrity Financial loss and loss of business due to contractual liabilities to third parties Loss of reputation and/or competitive advantage 2017 Jones Lang LaSalle IP, Inc. All rights reserved. Data Privacy Comply with data privacy laws governing the collection, use, storage and cross-border transfer of personal data of individuals Understand and control how your company and employees collect and handle personal data; even inadvertent access of personal data may result in data being captured and stored on your systems triggering violation of data privacy laws EU s General Data Protection Regulation (GDPR) has stringent requirements for protecting EU residents personal data. If you process personal data of EU residents in the course of providing services to JLL or our clients, then you must comply with GDPR regardless of whether you are based within or outside the EU 13

14 Labor and Employment Practices JLL respects and supports human rights principles as defined by the Universal Declaration of Human Rights, the International Labour Organization s Declaration on Fundamental Principles and Rights at Work, and the United Nations Global Compact We expect our suppliers to be equal opportunity employers and not engage in any discriminatory employment practices on the basis of race, caste, ethnicity or national origin, religion, age, disability, gender, sexual or gender identity or expression, union membership, political affiliation, covered veterans status or other such factors Suppliers must comply with all local minimum working age laws and requirements and meet, at a minimum, national or applicable local legal standards for payment of wages and benefits 2017 Jones Lang LaSalle IP, Inc. All rights reserved. 14

15 Workplace Health and Safety Create a safe and healthy work environment, whether in your own workplace or on JLL or client site Comply with all relevant health and safety laws and regulations as well as client, JLL and/or industry requirements Ensure that your employees are qualified, and equipped, to perform activities safely Develop appropriate health and safety procedures and provide resources to manage safety and ensure that your employees understand and properly apply safety standards and procedures Keep the workplace (whether your own or JLL/client premises) free of unauthorized drugs, weapons or devices Immediately inform JLL of any unsafe working conditions or any health or safety incidents that occur on JLL or client site 2017 Jones Lang LaSalle IP, Inc. All rights reserved. 15

16 Harassment and Abuse Workplace should be free of any abusive, harassing, threatening or offensive behaviour, whether verbal, physical or digital. Suppliers should not engage in or allow any physical discipline or abuse, or threats of physical discipline or abuse, or any sexual or other forms of harassment or intimidation. Behaviour should reflect civility and mutual respect and foster a safe and conducive working environment for your employees and third parties they interact with Suppliers should develop and implement a policy and measures that set a clear position on zero tolerance for harassment and management commitment to prevent and respond to any form of harassment 2017 Jones Lang LaSalle IP, Inc. All rights reserved. Key obligations of your company: Communicate JLL s Vendor Code of Conduct to your employees Investigate all reported cases thoroughly and take appropriate action Engage in an ongoing awareness and support campaign for all employees Train employees on workplace conduct and prevention of abusive behavior Report cases involving any incident on a JLL/client site to a senior JLL employee Do not retaliate against employees who report violations in good faith 16

17 Modern Slavery Modern slavery is illegal and a violation of human rights. These crimes share a common feature: exploiting vulnerable people for personal or commercial gain. It takes various forms, such as slavery, servitude, debt bondage, forced and compulsory labour and human trafficking. There are estimated 45.8 million people in modern slavery globally including in developed countries We are all legally, contractually and ethically bound to prevent modern slavery in our own operations and in our supply chain 2017 Jones Lang LaSalle IP, Inc. All rights reserved. Do Not: Ask your workers to deposit identity papers Restrict your workers movement Create abusive working / living conditions Impose or facilitate (through agents) debt obligations on workers for travel or accommodation You must also ensure that your supply chain does not engage in oppressive or unfair labor practices, including child labor, or knowingly engage a supplier or agent, that uses oppressive or unfair labor practices Vulnerable Sectors in JLL s Business Janitorial Food / Drink Landscaping Construction Security Services 17

18 Commitment to Sustainability People Promote health and well-being through safe, healthy workplace and conditions Embrace diverse skills and backgrounds and promote inclusion Communities Support disadvantaged, small and minority-owned businesses Volunteer time and money for charitable causes Planet Reduce greenhouse gas emissions Reduce environmental impact through recycling, waste management and acceptable levels of energy and water use Marketplace Champion fair business practices and healthy competition Foster transparency in supply chain 2017 Jones Lang LaSalle IP, Inc. All rights reserved. 18

19 Social Media Responsibility Exercise good judgment when dealing with social media. Do not intentionally or inadvertently post confidential or proprietary information (including pictures of client site) or anything that may negatively impact your relationship with JLL and its clients. Any social media communication on behalf of JLL or its clients must be authorized by JLL s communications department in writing. Do not use JLL or client systems or devices to create, access, store, print, or send any material that is intimidating, harassing, threatening, abusive, sexually explicit or otherwise offensive or inappropriate and/or send any false, derogatory or malicious communications Do not use the JLL logo or client logos without express written permission which may only be given for valid business reasons and in compliance with JLL s branding policies 2017 Jones Lang LaSalle IP, Inc. All rights reserved. 19

20 Three Pillars of Ethical Behavior Objectivity Client s/jll s best interests in mind No personal considerations Transparency Open dealings; no deception Good Judgment Does it fit with your and our values? How would it look in the newspaper? 2017 Jones Lang LaSalle IP, Inc. All rights reserved. 20

21 Report Unethical Behaviour If you see or suspect unethical behavior on JLL account, o o o o Report to a senior JLL person; or the JLL Ethics Officers at: or Report anonymously by calling the JLL Global Ethics Helpline at or logging a report on If the violation pertains to human trafficking, in addition to the above, you may contact the Global Human Trafficking Hotline at FREE or its address at JLL will keep all reports confidential to the extent permitted by law JLL practices a no retaliation policy for all reports made in good faith A Few Quick Tips If you know it s wrong, don t do it If you re not sure, ask your Legal Officer Remember, not reporting may also violate policies 21 Jones Lang LaSalle 2017

22 Questions? 22

23 2017 Jones Lang LaSalle IP, Inc. All rights reserved. 23

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