MODERN SLAVERY STATEMENT
CUSHMAN & WAKEFIELD
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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