I. POLICY 1. CBRE, Inc., referred to herein as CBRE or the Company, is committed to providing its employees with a work environment free from unlawful bias, discrimination and harassment and to promoting equal opportunity for all qualified employees without regard to race, color, religion, national origin, sex or sexual orientation, pregnancy, age, physical or mental disability, veteran status and all other protected classes under federal, state and local laws. Unlawful harassment, in whatever form and regardless of the intent, is a form of discrimination and interferes with our commitment to equal employment opportunity. It has no place at CB Richard Ellis. 2. In addition, CBRE is also committed to maintaining a workplace where employees are free from any form of harassment. Employees should be treated with dignity and respect. CBRE expects that its employees and other representatives of the Company will conduct themselves with integrity, professionalism and good judgment. Accordingly, verbal, physical or visual conduct by an employee that harasses disrupts or interferes with another s work performance or that creates an intimidating, offensive or hostile work environment will not be tolerated. The purpose of this Harassment Free Workplace Policy is to establish Company-wide standards regarding the prevention and investigation of both unlawful Harassment and other inappropriate behavior. 3. This Policy defines and establishes an absolute prohibition of all kinds of harassment in the work environment. In addition to setting forth examples of some forms of inappropriate behavior that could constitute Harassment, this policy establishes the Company s expectations and responsibilities of its supervisory personnel with respect to preventing, reporting and investigating harassment. In addition, this policy prohibits retaliation against anyone reporting harassment or participating in an investigation of such a report. 4. This Policy supersedes all pre-existing Sexual Harassment policies. II. PROVISIONS AND CONDITIONS 1. This policy applies to all employees of CBRE. This policy will be applied impartially to all employees, regardless of their rank, status, seniority or position within the Company. 2. Zero Tolerance of Harassment and Inappropriate Behavior: CBRE will not tolerate harassment and/or inappropriate behavior in the work environment. All forms of harassment, including unlawful harassment based
on sex, race, color, age or any other characteristic protected by state, local or federal law, are prohibited and will be grounds for appropriate discipline, up to and including termination of employment. In imposing the appropriate discipline, the Company will consider all of the circumstances surrounding the violation of this policy, including without limitation the severity of the offense. 3. Zero Tolerance of Retaliation: CBRE will not tolerate retaliation against any employee for making a complaint of Harassment or violation of this Policy, or for reporting inappropriate conduct to the Company or for providing information related to such complaint. Any employee found to have engaged in such retaliation will be subject to appropriate discipline, up to and including termination of employment. In imposing the appropriate discipline, the Company will consider all of the circumstances surrounding the violation of this policy, including without limitation the severity of the offense. 4. Investigation of Violations of this Policy: See HR Policy 4.2.9 Investigations of Legal and Ethical Misconduct. 5. Discipline: Violators of this policy will be subject to appropriate discipline, considering all facts and circumstances uncovered in the investigation, including without limitation written reprimands, monetary fines, suspensions, demotions and termination of employment. III. DEFINITIONS/EXAMPLES 1. The term harassment is any conduct that unreasonably interferes with another Employee s work performance or has the purpose or effect of creating an intimidating, hostile or offensive work environment. 2. State, local and federal laws define sexual harassment to include unwelcome sexual advances, requests for sexual favors, and other verbal, visual, or physical conduct of a sexual nature. Such conduct is unlawful when: A. Submission to the conduct is made a term or condition of employment; B. Submission to or rejection of the conduct is used as the basis for an employment decision affecting an employee; or
C. The conduct has the purpose or effect of unreasonably interfering with an employee s work performance, or creating an intimidating, hostile, or offensive work environment. 3. Examples of comments, actions or things that are inappropriate and could constitute unlawful sexual harassment include, but are not limited to: A. unwelcome sexual flirtations, advances, or propositions; B. verbal abuse of a sexual nature; C. any pressure or requests for sexual favors; D. unwelcome touching of an individual, including any form of assaulting, impeding or blocking movement, or any physical interference with normal work or movement directed at another individual; E. sexually-oriented kidding or teasing, practical jokes or jokes about gender-specific traits stories, cartoons, nicknames, and comments of a derogatory or sexual nature; F. displaying in the workplace of sexually suggestive objects or pictures (including downloading, storing or sharing sexually inappropriate text or images via internet pages, e-mails or e-mail attachments); sexually explicit or offensive jokes, or other materials containing sexually suggestive content. 4. The work environment covered by this policy extends beyond the Company s physical office locations and includes Company sponsored offsite meetings, events or conferences, or a client s office or a restaurant, or other location where Company business is conducted. Examples include sponsoring or attending a company event with co-workers, clients, and/or vendors any event or activity at a strip or gentlemen s club is a violation of this policy. See HR Policy 4.2.6 Inappropriate Entertainment for additional information on this topic. 5. The term retaliation is defined as any adverse employment action taken against someone for raising potential violations of this policy, reporting violations and/or participating in investigations. Examples of conduct that could constitute unlawful retaliation include, but are not limited to: unjustifiably terminating or refusing to promote an employee for making a complaint of harassment. IV. REPORTING POLICY VIOLATIONS 1. Any employee, who believes he or she has been the object of, or is aware of an instance of inappropriate behavior, harassment or retaliation, should promptly report the conduct as specified below. Complaints of sexual
harassment and/or retaliation may be made orally or in writing. Oral complaints will be documented appropriately. In addition, if an employee observes or experiences any offensive conduct, and believes it is sensible and appropriate to do so, he or she is encouraged to inform the offending party that the behavior is unwelcome and must stop. Often, an offending party may not realize that such behaviors are unwelcome or offensive; sometimes a simple discussion will promptly end the offending conduct. However, employees are not required to raise the offensive conduct with the offending party. 2. All supervisory and managerial employees have a duty to maintain a work environment free from all forms of harassment, including unlawful sexual harassment. Each supervisor and manager must immediately report any complaint or observation of unlawful Harassment or other violation of this policy to Human Resources. 3. Employees can report harassment, retaliation or inappropriate behavior through any of the avenues listed below: A. Their manager B. Any member of senior management C. The Human Resources Department* D. The HR Service Center* E. The Legal Department* F. The Chief Compliance Officer* G. The CBRE Ethics HelpLine at (800) 799-6523, an anonymous, confidential toll-free number administered by a third party for reporting claims, discussing concerns or asking questions about Harassment and the Company s policies and procedures. Additional information on the CBRE Ethics HelpLine is in the Standards of Business Conduct and on the Navigator. H. * Contact information for the Regional and Corporate Human Resources, the HR Service Center, Chief Compliance Officer and Legal Department contacts are located on the Ethics and Compliance Program page on the Navigator. 4. Note that under this policy an employee is not required to report violations of this policy through his/her direct chain of command, but may report such violations to any other person listed in Section V. (C) of this policy. V. INVESTIGATION PROCESS
See HR Policy 4.2.9 Investigations of Legal and Ethical Misconduct. VI. DISCIPLINARY ACTION FOR VIOLATIONS 1. Where it is determined that a violation of this policy has occurred, the Company will take appropriate corrective action and impose appropriate discipline. Such corrective action will be determined with the requirement that it be sufficient to discontinue the prohibited conduct. Disciplinary action may range from counseling, training and verbal warning to monetary fines or penalties, salary decrease, job reassignment, suspension or termination of employment. All disciplinary actions should be documented by the Company and placed in the violator s personnel file. 2. Employees who engage in harassment will be individually liable for damages to the harassed party. In addition, an employee whose conduct subjects the Company to liability for harassment shall be personally responsible to the Company for all expenses incurred by the Company, including the fees and expenses of litigation, costs, judgments, damages and settlements. 3. Any questions about this Policy should be directed to the Human Resources Department or the Chief Compliance Officer.