Modern Slavery Policy Pacific

 

1. Purpose

This policy is to be read in conjunction with CBRE’s (the Company) Global Human Rights Policy. CBRE has a strong commitment to social responsibility. In formulating and delivering our business strategy we take into account our responsibility to the community, environment, our people and our clients. 

The purpose of this policy is to:

  • ensure that the goods and services purchased through our supply and value chains are ethical and minimise or eradicate Modern Slavery risks;
  • set out the responsibilities of the Company and its subsidiaries, our employees, operations and suppliers in observing and upholding the Company's position on Modern Slavery; and 
  • provide information and guidance to our employees on how to recognise and deal with Modern Slavery issues.

This policy is endorsed by the Company's Board and senior management, who have ultimate responsibility for its implementation and references in this policy to the Company include a reference to all of the Company's subsidiaries. 

2. Scope

This policy applies to all directors of the Board, management, staff and contractors engaged and undertaking work on behalf of the Company, wherever they may be located (collectively referred to as personnel in this policy).  

This policy applies to our operations, activities and all of our dealings with third parties whether they be with private organisations, individuals or any representatives of such persons. Compliance with this policy is the responsibility of all Company personnel (irrespective of an individual's particular role or responsibilities).  

The Company expects our suppliers to uphold the same standards, including in dealings with their suppliers, and the Company commits to working in partnership with our suppliers to implement this policy.

3. Policy statement

Meaning of Modern Slavery

The Company defines Modern Slavery in accordance with the definitions provided in the Modern Slavery Act 2018 (Cth), that is, including slavery; servitude; forced labour; deceptive recruiting; forced marriage; debt bondage; trafficking in persons; and child labour. 

The Modern Slavery Act 2018 (Cth) requires all Australian entities or foreign entities carrying on business in Australia that have a consolidated revenue of $100 million or more, to publicly report on, amongst other things, risks of Modern Slavery in their operations (including investments and financial lending) and supply chains. 

Ethical Standards

The Company endeavours to ensure that we, and our personnel, comply with all laws related to Modern Slavery or Prohibited Business Practices (as described under ‘Dealing with Suppliers’ below), within our operations, activities and supply chains, endeavouring to ensure:

  • employment is freely chosen;
  • child labour is not used;
  • a living wage is paid to all individuals;
  • individuals are not required to work excessive hours;
  • entities promote a no tolerance discrimination policy; and
  • there is freedom of association and collective bargaining.

The principle of ethical behaviour also governs the conduct of all our procurement activities.  All personnel who procure goods, services, consultancy and capital work must comply with the standards of integrity, probity, professional conduct and ethical behaviour including:

  • to deal fairly, impartially and consistently with all suppliers;
  • to maintain the confidentiality of confidential and sensitive information obtained as part of the procurement process;
  • to formally declare any actual, potential or perceived conflicts of interest prior to the commitment of the procurement activity and abstain from any procurement activity where it has been deemed that an actual potential or perceived conflict of interest exists;
  • to examine and consider the integrity of the potential supplier, including the original source (where possible) of the product and whether there is the risk of any harmful labour practices or human exploitation (of any kind) based on the industry, location of the supplier or other factors; and
  • to ensure that the documentation is maintained so as to be able to reasonably demonstrate that procurement decisions and purchases were made in accordance with relevant procurement procedures and all other Company policies and applicable laws.

Dealing with Suppliers

The Company's approach to Modern Slavery and ethical business standards, including our expectations as set out in this policy, must be communicated in writing to all suppliers at the outset of our business relationship with them. Suppliers are required to comply with the Company's Supplier Code of Conduct and Human Rights Policy. The Company also encourages suppliers to implement their own binding guidelines for ethical behaviour.

Prohibited Business Practices

The Company requires all suppliers to comply with all applicable Australian and international laws in relation to prohibited business practices, and to support internationally accepted standards, treaties and declarations in relation to prohibited business practices, including (but not limited to) bribery and corruption; money laundering; financing terrorism; breaches of labour standards, including any form of exploitation or involuntary labour and workers' rights; breaches of modern slavery legislation; breaches of workplace health and safety laws; violations of human rights including discrimination in all its forms; breaches of privacy and data protection obligations; violations of trade and import rules; and unfair competition.

Modern Slavery 

We mandate that all our suppliers follow the following requirements related to risks of Modern Slavery before entering into any supplier contracts. 

  • Suppliers must not employ children under the legal age of employment in any country or local jurisdiction. If the minimum age of employment is not defined, it will be 15 years of age. Workers under the age of 18 must only perform work in accordance with legal requirements (eg with regards to working time, wages and working conditions) and subject to any requirement regarding education or training.
  • Suppliers must not use any form of forced, bonded or involuntary labour. All labour must be voluntary. Workers must be allowed to maintain control over their identification documents (eg passports, work permits or any other personal legal documents). The supplier must ensure that workers do not pay fees or make any payment connected to obtaining employment throughout the hiring process and the employment period. The supplier must be responsible for payment of all fees and expenses (eg licences and levies) relating to workers, where legally required.
  • Punishment and/or mental or physical coercion are prohibited. Disciplinary policies and procedures must be clearly defined and communicated to workers.
  • Suppliers must comply with all applicable national laws and mandatory industry standards regarding working hours, overtime, wages and benefits. Suppliers must pay workers in a timely manner and clearly convey the basis on which workers are being paid.
  • Deductions from wages as a disciplinary measure must not be allowed, if not legally permitted and even where legally permitted, should be minimised.
  • The workers of the supplier must be free to join or not to join a union/employee representation of their choice, free from threat or intimidation. Suppliers recognise and respect the right to collectively bargain in accordance with applicable laws.
  • Suppliers must promote an inclusive work environment valuing the diversity of its workers. The supplier must not discriminate or tolerate discrimination with respect to gender, race, religion, age, disability, sexual orientation, national origin or any other characteristic protected under applicable laws.
  • We expect our suppliers to strive to implement the standards of occupational health and safety at a high level by applying a health and safety management approach appropriate to their business. Suppliers must comply with applicable health and safety regulations and provide a work environment that is safe and conducive to good health, in order to preserve the health of workers, safeguard third parties and prevent accidents, injuries and work-related illness. This includes regular workplace risk assessments and the implementation of adequate hazard control and precautionary measures. Workers are to be adequately educated and trained in health and safety issues.

Supplier Compliance 

The Company reserves the right, upon reasonable notice, to check compliance with the requirements of the Supplier Code of Conduct. Any breach of the obligations stipulated in the Company's Supplier Code of Conduct are considered a material breach of contract by the supplier.

The Company requires suppliers to notify of any breaches (including any pending charges) of any laws related to Modern Slavery or Prohibited Business Practices as part of their commitment to full and frank disclosure for the protection of our business, our people, our clients and the community.

Training and Communication

Our employees who are likely to be exposed to modern slavery practices or risk factors will receive relevant training at appropriate intervals on how to implement and adhere to this policy. Suppliers will have the opportunity to receive training and will be contacted by the Company to organise this training.  

4. Roles, responsibilities and delegations

  • Board of Directors - Overall responsibility for ensuring this policy complies with the Company's legal and ethical obligations, and that all those under our control comply with it. 
  • Modern Slavery Committee - Ensuring CBRE is adequately managing Modern Slavery risks within the organisation and the supply chain and for assessing the effectiveness of the compliance program. This policy, and the Company's internal control systems and procedures, will be subject to regular reviews to provide assurance that they are effective in countering Modern Slavery.
  • Head of Ethics and Compliance, Pacific - Chairing the Modern Slavery Committee and primary contact in relation to this Policy. 
  • Management - Ensuring those reporting to them are made aware of and understand this policy and are given adequate training on it at appropriate intervals

5. Non-compliance with policy 

The Company supports and encourages personnel to raise genuine grievances about Modern Slavery matters, whether identified by, or affecting them, in the workplace.  We encourage our personnel and suppliers to report any instances that suggest that there is a risk, potential or actual, of Modern Slavery occurring in the supply chain, activities or operations of the Company or its suppliers or third parties. 

If you have any questions or need guidance in a particular case, you should consult a member of the Compliance team. The Company seeks to ensure that its personnel can raise concerns without fear that their future employment prospects will be adversely affected. If you wish to report a concern in relation to Modern Slavery, including any conduct that may be or result in a breach of this policy, you may raise it via the following:

  • Directly with a member of the Compliance team
  • Email the Compliance team at [email protected]
  • Report it via EthicsPoint
  • Report it by phone 1800 339 276.

If any person from CBRE engages in non-compliance with this policy, this may be considered as serious misconduct and could result in disciplinary action, up to and including termination. Any supplier of CBRE that engages in non-compliance with this policy may be subject of a review and subsequent termination of the contract with CBRE.

6. Related legislation and documentation

The Company has a number of policies and plans that deal with the risk, mitigation and management of Modern Slavery risks in its activities, operations and supply chains, including:

  • Supplier Code of Conduct;
  • Human Rights Policy; and
  • Whistle-blower Policy

Who to Contact

Director of Ethics and Compliance, CBRE
[email protected]
 
Ethics and Compliance Officer. CBRE
[email protected]