MODERN SLAVERY STATEMENT
2025 Financial Year
MODERN SLAVERY STATEMENT
CUSHMAN & WAKEFIELD
TABLE OF CONTENTS
04 06 10 14 16 2 4
Introduction
About this Statement
Risks of Modern Slavery
Ethical Sourcing Framework
Mitigation
Assessing Effectiveness
2 5
Further Steps
ACKNOWLEDGEMENT OF COUNTRY Cushman & Wakefield respectfully acknowledge First Nations peoples as the Traditional Owners of the land on which we work, live and operate, and we pay our respect to their Elders past and present in maintaining the culture and spiritual connection to the land.
We recognise that this is, always was, and will always be land that belongs to First Nations peoples.
Artwork: Ngumbaay Ngurambang (“One Home” in Wiradjuri) by Nathan Peckham.
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INTRODUCTION
As a leader in the commercial real estate industry, Cushman & Wakefield has a responsibility to oppose all forms of modern slavery. We remain firmly focused on working to eliminate all forms of modern slavery from our operations and supply chain through a targeted, risk-based approach. We remain committed to continuously reviewing and improving our approach to how we manage these risks. We acknowledge that meaningful progress requires collective action. We therefore continue to work closely with our partners and industry peers to drive the eradication of all forms of modern slavery across our industry. Cushman & Wakefield’s operating philosophy is to never settle for a world that has been built, but to relentlessly drive it forward, because ‘Better Never Settles’. This purpose describes both the journey and our culture. With energy and determination, we remain focused on advancing outcomes for our clients and building stronger, more transparent relationships across our supply chain, enabling us to address modern slavery risks more effectively for the good of everyone.
As CEO, I take very seriously my responsibility to ensure that we respect human rights in everything we do. This responsibility extends to our people, our clients, our suppliers and the communities in which we operate. As a global provider of commercial real estate and facilities management services, we are driven to address complex challenges within the built environment. Our people are the foundation of our success, and it is through their commitment and proactive efforts that we continue to strengthen how we prevent and respond to modern slavery risks across our business and supply chains. It is my pleasure to introduce our sixth Modern Slavery Statement, which reflects our ongoing commitment to the fair and respectful treatment of all stakeholders. Throughout FY25, we have further enhanced our processes for identifying and assessing modern slavery risks at Cushman & Wakefield and throughout our supply chain. By expanding our collaboration with industry partners and suppliers and investing in improved training and communication for our people, we continue to strengthen our ability to detect and address these risks.
Noral Wild CEO, ANZ and North Asia Cushman & Wakefield
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ABOUT THIS STATEMENT
OUR BUSINESS AND OPERATIONS
Cushman & Wakefield’s business is organised into the following six core groups:
Cushman & Wakefield in Australia employs around 1,400 people, offering comprehensive real estate services to occupiers and investors. As one of the leading global real estate firms, Cushman & Wakefield provides a wide range of services including property management, brokerage, investment management, and advisory. With a strong presence across major Australian cities, the company leverages its extensive market knowledge and expertise to deliver tailored solutions that meet the unique needs of each client. Cushman & Wakefield is committed to driving value and performance for both occupiers and investors in the dynamic Australian real estate sector. • Commercial Real Estate Services; • Project & Development Services; • Advisory Services; • Global Occupier Services; and • Business Operations (including Human Resources, Legal, Ethics & Compliance, Information Technology, Marketing, Communications & Research and Finance). • Integrated Facilities Management (including Facilities Management, Trades Services, Workplace Services and Asset Services);
This is a joint Modern Slavery Statement from Cushman & Wakefield Pty Ltd (ACN 074 196 991), DTZ Australia Pty Ltd (ACN 106 515 931), DTZ Aus Holdco Pty Ltd (ACN 602 106 936) and DTZ Aus Bidco Pty Ltd (ACN 169 965 995), issued under the Australian Modern Slavery Act 2018 (Cth) (Act). For the purposes of this Modern Slavery Statement, the reporting entities and the entities that they control or own are together referred to as ‘we’, ‘us’, ‘our’ or ‘Cushman & Wakefield’, whereas Cushman & Wakefield refers to our global group. This Modern Slavery Statement covers the reporting period of 1 January 2025 to 31 December 2025. Founded in 1917, Cushman & Wakefield is a full-service global real estate services leader, driven to solve complex problems in the built environment. Our core values drive our business forward, inspire innovation and ensure that we deliver service excellence every day. Across our global platform, we remain committed to ethical conduct and responsible business practices. In Australia, we leverage our global platform with local expertise nationwide to serve a diverse range of clients across the public, private and government sectors. Across Cushman & Wakefield, our values guide us to maintain a strong commitment to safety, integrity and diligence.
OUR SUPPLY CHAINS The unique and tailored services we continue to deliver to our clients often require us to build multi-tiered supply chains. In Australia, we work with around 3,350 suppliers, with our most complex supply chains being built within our Integrated Facilities Management (IFM) business.
Our strategic priorities
At Cushman & Wakefield, our strategic priorities shape our business operations and how we work with our partners and stakeholders. These priorities have been designed to ensure that Cushman & Wakefield continues to build as a resilient, forward-thinking and thriving company, continuously driving solutions for our clients.
In FY25, our Australian IFM business recorded total supplier spend of A UD $497.68 million, supporting 95 diverse clients across sectors including banking, retail, and government agencies.
Cushman & Wakefield’s strategic priorities remain:
CLIENT TOTAL SPEND
40.00%
35.00%
30.00%
DRIVING GROWTH
STRENGTHEN THE CORE
OPERATE WITH RIGOR
25.00%
20.00%
We are committed to continuing the momentum in our core business. This includes building on our financial strength, continuing our dedicated client focus and owning the narrative to ensure that we are known as the premium brand in our industry.
Across the organisation, we strive for financial flexibility and rigorous prioritisation, measuring progress and holding ourselves accountable while empowering decision- making to better serve our clients. We continue to build on our focus on developing a high-performance culture, supporting our people and making the organisation more diverse and inclusive.
We continue to evolve our business for the long view, shifting our focus to longer-term growth, in both revenue and market-share as well as growth in key client segments.
15.00%
10.00%
5.00%
0.00%
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Cushman & Wakefield is committed to upholding and championing ethical and sustainable business practices across all areas of our operations. This commitment is central to our supplier selection and management processes. Our supplier network provides a broad range of goods and services. Most of our property service providers are based in Australia, with a small number of international suppliers. Regardless of location, we apply the same high ethical standards and maintain a zero-tolerance approach to any type of modern slavery. We continue to monitor and assess supplier compliance at all levels to ensure alignment with our values and expectations. As a key part of the larger global Cushman & Wakefield organisation, we benefit from some centralised services. However, our global platform shares the approach of our Australian business and is always conscious of the global nature of supply chains. We are committed to ensuring that all our suppliers, no matter where they are located, adhere to our core values and ethical practices. Throughout FY25, we continued to refine our approach to mapping and monitoring modern slavery risk by enhancing our robust supplier management processes. Our ongoing supplier engagement gathers important insights into labour practices, ensuring our risk priorities reflect operational realities as well as our high standards of ethical and sustainable business practices. Our ongoing efforts to improve processes demonstrate our continued commitment to maintaining strong, ethical and long-lasting relationships with all our suppliers. Cushman & Wakefield’s Procurement team plays a critical role in identifying, assessing and mitigating modern slavery risks within the firm’s operations and supply chains. Procurement influences supplier selection, contracting, ongoing supplier management and risk monitoring, and supports Cushman & Wakefield’s broader human rights and ESG commitments. Our approach to managing Modern Slavery Risks in our operations and supply chains
TRANSPARENCY AND ACCOUNTABILITY
We uphold transparency in our business practices and continue to report on our efforts to address modern slavery risks through both internal and external channels.
CONTINUOUS IMPROVEMENT
While we acknowledge the progress we have achieved to date, we also recognise that managing modern slavery risks is a continuous and evolving effort. As such, we continue to review and refine our policies, procedures and practices to ensure they remain effective and aligned with emerging best practices. We are committed to meeting our obligations under all modern slavery legislation. Upholding fundamental human rights is non-negotiable and we expect the same commitment from our partners and suppliers. Our employment practices are founded on principles of merit and freedom of choice, with no tolerance for coercion or forced labour. Throughout our operations and supply chain, we maintain a steadfast commitment to ethical standards. Our primary objective is to work actively to mitigate potential risks and liabilities associated with modern slavery, in full compliance with the Act and in line with our values and policies. We are dedicated to fostering a culture of responsibility and accountability across our organisation, encouraging employees to speak up and striving to uphold fundamental human rights and prevent any form of exploitation or abuse. In our sixth annual Modern Slavery Statement, we provide a comprehensive account of Cushman & Wakefield’s ongoing efforts to identify, address, and mitigate modern slavery risks across our operations and supply chain. We remain committed to continuously evaluating the efficacy of our actions and maintaining transparency in our process. Through this transparency, we aim to sustain our positive influence across our industry, always striving for best practice.
POLICY COMMITMENT
Cushman & Wakefield maintains a zero-tolerance policy towards modern slavery and human trafficking. This commitment is embedded in our values and is reflected in all aspects of our business operations. Our Global Code of Business Conduct and our Global Vendor/ Supplier Integrity Policy codify this commitment. We expect the same commitment from all business partners and suppliers.
This Statement has been prepared with the input of relevant subject matter experts across the business. At Cushman & Wakefield, we take a unified approach to addressing modern slavery.
RISK ASSESSMENT
Risk assessments carried out across our business allows us to identify and focus efforts on areas within our operations and supply chain where there may be a risk or perceived risk of modern slavery.
SUPPLIER ENGAGEMENT
We work closely with our suppliers to understand their labour practices and ensure alignment with our ethical expectations. All suppliers are required to comply with applicable laws and regulations, including those related to modern slavery.
EMPLOYEE TRAINING
In FY25, we updated our employee training program to ensure continued strength and improvement, to build awareness of modern slavery and equip employees with the tools to identify red flags and report suspected cases. This approach supports a more informed and proactive workforce.
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RISKS OF MODERN SLAVERY
RISK ANALYSIS
Our primary objective is to work actively with our suppliers and internal stakeholders to identify, assess, and address the risk of modern slavery across our operations and supply chain. We assess risk using a combination of factors, including: • Geographic location – countries or regions with higher prevalence of modern slavery; • Industry sector – sectors known for vulnerable workforces or complex subcontracting arrangements; • Labour practices – workforce characteristics such as reliance on migrant or low-skilled labour; • Procurement category – categories with known risks, such as cleaning, construction, or PPE; and • Supplier responses – insights gathered through our Supplier Assessment Questionnaire (SAQ). This multi-dimensional approach enables us to focus on higher-risk areas and prioritise engagement where it can have the greatest impact.
Risks to ethical sourcing standards within our supply chain can include: • Excessive working hours; • Working visa conditions;
SELF-ASSESSMENT QUESTIONNAIRE (SAQ)
• Intentional and unintentional underpayment; • Retention of worker’s identity documents;
Our Supplier SAQ evolved significantly during FY25 to strengthen supplier engagement and deepen our understanding of modern slavery risk across our network. We identified that 379 of our suppliers are part of the Informed365 consortium. Each of these suppliers received the consortium SAQ. Additionally, we identified 345 suppliers from Commercial Services & Supplies (such as cleaners, security, landscaping, general building, catering, appliance repairs) and Construction & Engineering (30 in total) industries which are not part of consortium. These contractors received our “Lite” SAQ. Overall (out of total 729 suppliers) engagement rate was 10.56%. We did not identify any High or Very High risk suppliers.
• High levels of sub-contracting; and • Fear of retaliation for speaking up .
During FY25, we refined our approach to mapping and monitoring modern slavery risk by deepening collaboration with our industry partners and suppliers, while sharpening our market insights.
INDUSTRY COLLABORATION
Throughout FY25, we continued to actively participate in monthly Property Council of Australia – Informed365 consortium meetings, working alongside peers to review emerging issues and validate industry and geographic risk ratings. As part of these sessions, we continued to align our risk indicators with industry best practice and emerging trends. Ongoing access to IBIS World industry reports further strengthened our understanding of sector-specific risks.
SME-TARGETED “LITE” SAQ
We continued to utilise the streamlined version of our SAQ, tailored for small and medium enterprises (SMEs). This captures critical indicators of modern slavery risk with a 40% reduction in the number of questions asked. Designed to increase participation among lower-resourced suppliers, this version ensures meaningful insights without compromising data quality.
KEY STAKEHOLDER ENGAGEMENT
In 2025, we engaged regularly with key suppliers, procurement leads, internal client account teams and regional directors to gather frontline insights into labour-related risk exposure. Through these ongoing meetings and dialogue, we ensure our risk framework accurately reflects operational realities and upholds our ethical standards. We also worked closely with key clients to assess and review modern slavery risks at certain higher risk sites, including completion of an assessment of our vendors’ approach to managing their modern slavery risks at those sites.
DEEP-DIVE MODULES FOR HIGH-RISK SECTORS
We continued to enhance sector-specific deep-dive modules for high-risk categories such as cleaning and grounds maintenance. These modules explore targeted risk controls, including wage audit protocols, worker interviews and grievance mechanisms, helping us better understand risk dynamics in these areas.
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SUPPLY CHAIN SEGMENTATION
PLATFORM ENHANCEMENTS VIA INFORMED365
In FY25, significant improvements were made to the Informed365 platform interface and functionality, including the update of the modern slavery dashboard with new views on inherent risk, supplier engagement, and reporting insights. Updated features include:
During FY25, we continued to utilise four risk-exposure categories to focus our resources to have the most significant impact on our modern slavery assessments and continued to refine each segmentation. The enhancements are:
• Automated reminders for assessment completion; • Flags for third-party verification or overdue responses; • Supplier Guide with help articles for suppliers completing the SAQ; and • Intuitive navigation to track risk by sector and supplier.
SCORING & EVALUATION FRAMEWORK
A proposed “Tier-1 sub-tier” to identify suppliers with more than 50% of operations or supply chain exposure in high-risk geographies, supporting more frequent compliance engagement, potentially on a quarterly cycle.
Bi-annual risk review calls and communications to strengthen engagement with smaller providers and facilitate the sharing of modern slavery risk mitigation practices.
Informed365 incorporates a risk-based scoring and weighting system to assess supplier responses. Each SAQ question is rated for relevance to modern slavery, allowing us to focus on higher-impact areas. Although adoption remains voluntary, we continue to explore alignment to support structured evaluations and industry benchmarking.
CONTINUOUS IMPROVEMENT PATHWAYS
Responses to five key questions in the SAQ trigger automated continuous improvement pathways. Where gaps are identified, suppliers receive tailored feedback, practical resources, and targeted actions. Progress is monitored over time to track improvements and build supplier capability.
We continue to develop our approach to streamlining monitoring through annual desktop reviews and automated de-risking functionality integrated across our sourcing, supplier registration and spend analytics platforms.
A random audit mechanism is under development to validate ongoing compliance, with a particular focus on suppliers demonstrating irregular or fluctuating spend patterns.
ONGOING QUESTION SET REFINEMENT
Through our active participation in the Property Council of Australia – Informed 365 Consortium in FY25, we continued to refine the questions in our SAQ. Feedback informed the clarification of language, removal of non-actionable questions and continued improvements to ensure greater relevance for our specific supply chain.
HIGH-RISK INDUSTRIES
• Labour intensive services (e.g. cleaning, security, landscaping, fit out and construction); • Spend categories with complex or multi tier supply chains; and • Use of temporary labour, subcontracting or migrant workers. In FY25, the Procurement team continued to systematically identify areas of higher modern slavery risk across goods and services procured, with particular focus on:
In 2025 our actions included:
• Applying a risk-based approach to supplier segmentation; • Using supplier self assessment questionnaires to capture workforce, labour practices and subcontracting data; and • Leveraging third party risk tools to identify red flags.
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ETHICAL SOURCING FRAMEWORK
ETHICAL SOURCING SPOT CHECKS & AUDITS
Cushman & Wakefield is committed to preventing and remedying non-compliance in our supply chain. We set expectations of our suppliers from supplier registration, continuing through our Global Code of Business Conduct, our Global Vendor/ Supplier Integrity Policy and related policies. Ethical sourcing spot checks and audits help us to verify the performance of our suppliers and allow us to measure risk objectively, monitor compliance and identify any issues to address. They initiate open dialogue with suppliers on ethical standards and expectations and can act as a catalyst to drive positive change. Where deemed necessary or appropriate - typically based on risk, allegations, or client request - Cushman & Wakefield carries out spot checks or audits. These activities provide a pragmatic, risk-based approach to help ensure adherence to ethical sourcing standards.
Through our clear ethical standards, our risk management policies and framework and our proactive auditing program, we continue to manage risk, have clear visibility, uphold standards and values and safeguard human rights.
Our Ethical Sourcing Framework ensures responsible and sustainable supply chain management. It promotes fair treatment of workers, minimises environmental impact and follows the internationally recognised ‘Base Code’ for ethical practices. This code includes clauses on freely chosen employment, respect for collective bargaining, safe working conditions, no child labour, fair wages, reasonable working hours, no discrimination, recognised employment relationships, and prohibition of harsh treatment. The Ethical Sourcing Framework consists of three steps and supplements our overarching risk management framework. Each supplier is individually assessed, inherent industry risk is considered, and a risk rating is applied. Risk ratings define spot check frequencies, and any non-conformance informs possible further action to be decided by a risk committee, e.g. targeted investigations or external independent audits.
Criteria assessed include: • Business legitimacy and integrity of records; • Instances of underage labour; • Discrimination and disciplinary practices;
• Freedom of association and the effective recognition of the right to collectively bargain; • Harassment and abusive practices; • Wages, benefits and terms of employment; and • Subcontracting compliance.
• Instances of forced labour; • Working hours and overtime;
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MITIGATION Cushman & Wakefield maintains rigorous supplier management practices, constantly refining and expanding these measures in alignment with our commitment to counteract modern slavery risks. In compliance with the Act, we continue to enhance governance in our registration and procurement processes. Additionally, we work to emphasise training and raise awareness to understand and combat these risks.
We have developed a standard approach, compliant with the Act, to serve as a model for incorporating similar strategies across other company sectors. Our aim is to detect and reduce the risk of modern slavery throughout our supply chains, reinforcing our commitment to ethical business practices. This includes: • Identifying, assessing and monitoring potential risk areas in our supply chains; • Ensuring that high-quality spend and engagement data is held and analysed; • Engaging suppliers through a procurement process that considers and assesses modern slavery risk; • Providing a mechanism to report suspected incidents of modern slavery; and • Establishing a process for investigating incidents and engaging with suppliers to remediate identified modern slavery risks where appropriate.
The measures outlined below are a critical aspect of our mitigation strategy. They serve as the foundation for future implementation across all areas of our business in upcoming reporting periods.
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PROCUREMENT PROCEDURE Cushman & Wakefield sources a wide range of goods and services in accordance with its ANZ Procurement Policy and related sourcing, procurement and contract management procedures. ‘Procedures’ are standard procurement processes and are steps that: In FY25, we built on the comprehensive review of our procurement documentation, to align more explicitly with modern slavery obligations. This included an update to our templates and tender process, which now include targeted questioning on supplier history with the Fair Work Ombudsman, compliance with labour laws, child and forced labour prohibitions, supply chain due diligence practices and the maintenance of employment records. These updates enhance transparency, drive accountability and enable more informed supplier evaluations. Can evolve for continuous improvement 01 02 Enable users to do their work effectively within the specified guidelines.
The Procurement team works closely with Account Teams, Ethics & Compliance, Legal and EHS teams to ensure appropriate response and remediation.
In 2025 our actions included:
• Ensuring completion of a due diligence assessment by all registered suppliers, including provision of responses in relation to their compliance with the Act. Contractors who did not complete this requirement were suspended from operations with Cushman & Wakefield; and • A further full review of our SAQ by the Procurement team. These updates are currently pending a review by internal stakeholders, with the view to ensuring completion of the update in FY26.
COMPANY POLICIES
Cushman & Wakefield’s Global Code of Business Conduct and Global Vendor/Supplier Integrity Policy underpins how we conduct business. These documents reflect our company’s zero-tolerance stance towards modern slavery, detailing our structured reporting channels and whistleblowing mechanisms. Through these policies, Cushman & Wakefield can effectively review and monitor supplier adherence to our ethical principles. Integral to our commitment, all new suppliers must accept the Global Vendor/Supplier Integrity Policy during their onboarding process. Ensuring transparency and responsibility, both the Global Code of Business Conduct and the Global Vendor/Supplier Integrity Policy are publicly accessible on our website, demonstrating our alignment with the requirements of the Act. Responsible Sourcing Procurement Policy At Cushman & Wakefield, we believe that through ethical sourcing, we are responsible for the impact that our business decisions have on the people and communities through our supply chain. During FY25, we continued to train employees on the Global Responsible Sourcing Policy which sets out our expectations around ethical, social and environmental performance across our procurement and supply chain activities. This policy, which is aligned with our Global Code of Business Conduct and sustainability goals, outlines supplier obligations to uphold human rights, avoid modern slavery and implement robust risk identification and mitigation frameworks. The Responsible Sourcing Procurement Policy guides our ethical purchasing practices.
SUPPLIER DUE DILIGENCE AND ONBOARDING
Our Contractor Registration Team embeds modern slavery considerations into the supplier onboarding and review process by: Requiring all suppliers to confirm compliance with Cushman & Wakefield’s: o Global Vendor/Supplier Integrity Policy; o Anti-Bribery and Corruption Statement; o General Terms & Conditions; and o Applicable labour laws and global human rights standards, all of which include Modern Slavery commitments . Requesting copies of supplier modern slavery statements or equivalent policies where required by law; Including modern slavery-related screening in RFPs and tender assessments; and Assessing suppliers’ use of subcontractors and labour hire arrangements.
This ensures modern slavery risk is assessed before commercial relationships are formalised.
ONGOING SUPPLIER MANAGEMENT AND MONITORING Once suppliers are onboarded, Cushman & Wakefield’s Procurement team manages the ongoing monitoring of suppliers through:
• Periodic supplier reviews with a focus on higher risk categories; • Monitoring for changes in supplier risk profile (location, ownership, workforce practices);
• Supporting remediation activities where concerns are identified; and • Escalating suspected breaches through internal governance pathways.
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SUPPLIER ADHERENCE
We implement various measures across different parts of our business to reinforce our zero-tolerance stance on modern slavery throughout our supply chain, including:
• Conducting due diligence risk assessments; • Clearly and continuously communicating our ethical expectations to suppliers; • Requiring suppliers to accept and comply with our Global Code of Business Conduct and related policies; • Clauses in our standard supplier agreements that explicitly prohibit modern slavery, impose reporting and record-keeping obligations, and grant us termination rights for any breaches; and • Incorporating questions into tender documentation to assess the steps tenderers take to address modern slavery within their organisations.
CONTRACTUAL OBLIGATIONS AND AUDIT RIGHTS
TRAINING
We provide targeted training to equip our people with the knowledge and skills to identify and respond effectively to ethical risks, including those related to modern slavery. Our program focuses on raising awareness, highlighting red flags to be aware of and ensuring a clear understanding of the appropriate actions to take to mitigate potential issues within our operations and supply chain. During FY25, we developed a new on-demand modern slavery training module, released through our HR and training platform Workday. This training is available to all employees in our Australian business and is mandatory for all employees who work closely with suppliers. It ensures consistent awareness of modern slavery risks and clear understanding of reporting pathways. This training reflects our ongoing commitment to equipping employees with the skills to recognise and address ethical risks effectively. MODERN SLAVERY STATEMENT Since the implementation of the Modern Slavery Act on 1 January 2019, Cushman & Wakefield has consistently released an annual Modern Slavery Statement, as required by the Act. Our compliance journey reflects a strong and ongoing commitment to recognising and addressing modern slavery risks across both our operations and supply chain. Each year, we deepen our understanding and identify new opportunities to strengthen our approach. The robust reporting requirements under the Act not only enhance our awareness of modern slavery risks but also highlight our proactive measures to mitigate them and drive progress toward eliminating such practices from our industry. Our annual Modern Slavery Statement serves as a key mechanism for reporting on our progress as well as future priorities, both internally and externally. In presenting our sixth Modern Slavery Statement, we continue to build upon the groundwork established in previous years, demonstrating greater program maturity and a more informed perspective on modern slavery risks we face.
Compliance obligations specifically relating to modern slavery are fully incorporated into our standard supplier contract templates, procurement documentation and supplier registration process. Our supplier contracts and Cushman & Wakefield’s Global Vendor/Supplier Integrity Policy also allow our internal auditors to monitor, test and audit our suppliers’ compliance with their contractual obligations. We continue to adapt and expand our audit and spot check processes to address supplier compliance with modern slavery obligations.
No deficiencies in respect of modern slavery practices were reported as part of these audits and spot checks during the Reporting Period.
WHISTLEBLOWING PLATFORM
In line with our core protocols for reporting modern slavery risks and ethical concerns, Cushman & Wakefield continued to strengthen awareness of and access to our global whistleblowing platform during FY25. This secure channel enables employees, suppliers and other external stakeholders to report suspected instances of modern slavery, with the option to remain anonymous. Our enhanced framework, governed by the Global Whistleblowing Policy, ensures that all disclosures are treated confidentially and without risk of retaliation. We are committed to fostering a culture of transparency, where individuals feel supported and safe to speak up. Our employees receive regular training to reinforce this commitment. Key actions undertaken in FY25 to improve accessibility and visibility included targeted training on speaking up when concerns are raised, together with provision of information on red flags for employees to be aware of. Anyone wishing to raise a Modern Slavery concern may also request a meeting with a member of company management, Ethics & Compliance, Legal or Human Resources. Once notified, the receiving representative must promptly inform a member of the Ethics & Compliance team to ensure appropriate follow-up and oversight.
Our commitment to accountability remains steadfast, and we will continue to evolve and enhance our strategies to effectively address modern slavery within our sphere of influence.
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REPORTING POLICY AND RESPONSE PLAN
In addition to our Whistleblowing platform, Cushman & Wakefield further developed its response and governance framework to formalise how we address modern slavery allegations.
Cushman & Wakefield has a Modern Slavery Risk Committee (the Committee) as part of our governance structure. The Committee comprises senior management and representatives from Procurement & Supply Chain, Legal, Ethics & Compliance and EHS teams. It is responsible for investigating potential or actual incidents of modern slavery within our operations and supply chains. Our response plan follows this high-level approach, if a potential instance of modern slavery is identified and reported by an employee, contractor, or personnel of Cushman & Wakefield: • The Committee will be notified of the potential instance and urgently convened to review the report; • The Committee will assess the allegation and agree on the appropriate course of action; • If necessary, the Committee will establish an investigation team or working group to gather evidence, conduct a detailed assessment, and report findings, conclusions, and recommendations back to the Committee; • Based on risk and investigation outcomes, the issue may be escalated to senior stakeholders, including Regional (APAC) and Global Ethics & Compliance leadership; and • If a case of modern slavery is identified or strongly suspected, the Global Chief Ethics & Compliance Officer and relevant government authorities will be notified as required.
REMEDIATION If we identify non-compliance with our policies or determine that an individual has been harmed by a supplier’s actions, we will work collaboratively with that supplier to address and resolve the issue. We also have processes to investigate the root causes and implement measures to prevent recurrence - both with the specific supplier involved and across our broader supplier network. If a supplier fails to make adequate progress on required remediation, we may review the relationship and, where appropriate, impose sanctions - including the potential termination of our engagement.
During the Reporting Period, no instances of modern slavery were identified within our operations.
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ASSESSING EFFECTIVENESS We assess the effectiveness of our modern slavery risk management approach through a combination of metrics, insights, and ongoing review processes, with a particular focus on higher-risk areas within our IFM activities. Given the nature of our operating model, we place emphasis on monitoring risks associated with labour- intensive services delivered through subcontractors and service providers. Key performance indicators include supplier risk screening and due diligence coverage, audit outcomes for higher-risk vendors, completion of training across relevant teams and the timely implementation of corrective actions where issues are identified.
We also assess broader outcomes, including improvements in supplier transparency and the effectiveness of our speak up mechanisms in identifying and addressing potential risks within our managed sites.
This approach is supported by continued internal review and engagement with industry initiatives, enabling us to benchmark our performance and track progress over time. This ensures we continue to evolve our response, with a focus on strengthening controls and enhancing our ability to identify risk. Over time, we aim to further refine our approach by expanding outcome-focused metrics, particularly in relation to supplier behaviour and worker outcomes, to better assess the extent to which our actions are reducing the risk of modern slavery within our sphere of influence. We consider our contractual audit rights with our suppliers to be one of the most effective methods of evaluating the effectiveness of our modern slavery mitigation practices detailed in this Modern Slavery Statement. Additionally, our internal EHS team conducts audits, which incorporate modern slavery components.
FURTHER STEPS
Cushman & Wakefield Australia is committed to continuing and enhancing its modern slavery risk mitigation strategy in the long term.
APPROVAL The Statement is jointly made by Cushman & Wakefield Pty Ltd (ACN 074 196 991). DTZ Australia Pty Ltd (ACN 106 515 931), DTZ Aus Holdco Pty Ltd (ACN 602 106 936) and DTZ Aus Bidco Pty Ltd (ACN 169 965 995) for the financial year ending 31 December 2025. This Statement had been approved by the sole director of Cushman & Wakefield Pty Ltd on behalf of itself and in consultation with and on behalf of the other reporting entities covered by the Statement, pursuant to section 14(2)(d)(iii) of the Modern Slavery Act 2018 (Cth).
Noral Wild CEO, ANZ and North Asia Cushman & Wakefield
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About Cushman & Wakefield
Cushman & Wakefield (NYSE: CWK) is a leading global commercial real estate services firm for occupiers and investors with approximately 53,000 employees in over 350 offices and nearly 60 countries. In 2025, the firm reported revenue of $10.3 billion across its core service lines of services, Leasing, Capital markets, and Valuation and other. Built around the belief that Better never settles , the firm receives numerous industry and business accolades for its award-winning culture. For additional information, visit www.cushmanwakefield.com.
For additional information, visit www.cushmanwakefield.com.
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