MODERN SLAVERY STATEMENT
CUSHMAN & WAKEFIELD
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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