MODERN SLAVERY STATEMENT
CUSHMAN & WAKEFIELD
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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