Cushman & Wakefield Modern Slavery Statement FY25

MODERN SLAVERY STATEMENT

CUSHMAN & WAKEFIELD

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;