Vendor Code Of Conduct - JLL

Avoid the appearance of or actual improprieties orconflicts of interests. Vendors or their representativesshall not deal directly with any JLL or client employeewhose spouse, domestic partner or other familymember or relative holds a significant financialinterest in the vendor. Dealing directly in the courseof negotiating the vendor agreement or performingthe vendor’s obligations with a spouse, domesticpartner or other family member of relative who isemployed by JLL or client is also prohibited.Avoid insider trading by not buying or selling JLLor client stock when in possession of materialinformation about JLLor the client that is notavailable to theinvesting public andthat could influence aninvestor’s decision tobuy or sell such stock. Takereasonable steps toprotect against allforms of cyber-attacks or other intrusions intoelectronic systems as the result of which data of JLLor its clients may be lost, stolen or corrupted.Further to that, we expect our Vendors to, at a minimum: comply with all relevant health and safety laws andregulations as well as client, JLL and/or industryrequirements; demonstrate a cultural commitment to maintaining asafe working environment; ensure employees are qualified, and equipped, toperform activities safely; develop health and safety procedures that arerelevant to the activities of the Vendor, and in keepingwith appropriate best practices; provide resources to manage safety and to ensurethat personnel understand and, properly apply, safetystandards and procedures; immediately inform JLL of any health and safetyincidents that occur while performing services for, ordelivering goods to, JLL or its client; ensure employees (or others under the vendor’scontrol) do not possess weapons of any kind when atJLL offices or managed properties.We are building a strong safety culture, and health andsafety performance and awareness will play a key role inour Vendor selection process.Health and SafetyJLL is fully committed to providing a workplacethat prevents injury and ill-health and ensures thatall people return home to their families safely.We recognize that we cannot achieve this goal on ourown, but rather need the support, commitment anddedication of all our business partners, including ourVendors. Our corporate aspirations are outlined in ourGlobal Health and Safety Policy, and we expect all ourVendors to aspire to achieve similar safety goals.Vendor Code of ConductJanuary 20169

Employment practicesand undertaken in accordance with, local law andethical practice and does not interfere with thatindividual’s health and well-being. We only supportthe development of legitimate workplaceapprenticeship programs for the educational benefit ofyounger people and will not do business with thosewho abuse such systems.As a good corporate citizen, JLL respects and supportshuman rights principles as defined by the UniversalDeclaration of Human Rights (UDHR), the InternationalLabour Organization’s Declaration on FundamentalPrinciples and Rights at Work (“ILO Declaration”) and theUnited Nations Global Compact. JLL expects its vendorsto share our commitment to human rights and equalopportunity in the workplace. JLL vendors shall conducttheir employment practices in full compliance with allapplicable laws and regulations, and shall: Cooperate with JLL’s commitment to a workforce freeof harassment and unlawful discrimination. While werecognize and respect cultural differences, we believethat vendor companies should not engage indiscrimination in hiring, compensation, access totraining, rewards, promotion, termination, orretirement based on race, color, caste, ethnicity ornational origin, religion, age, disability, gender, maritalstatus, pregnancy, sexual orientation, sexual orgender identity or expression, union membership,political affiliation, covered veterans status, orprotected genetic information. Prohibit the use, possession, distribution and sale ofillegal drugs while on JLL owned, leased, or managedproperty. Prohibit the possession of unauthorized weaponswhile on JLL owned, leased, or managed property. Use only voluntary labor. The use of forced laborwhether in the form of indentured labor, bonded labor,or prison labor by a JLL vendor or its subcontractorsis prohibited. Not require workers to lodge “deposits” or theiridentity papers with their employer and keep themfree to leave their employer after reasonable noticewithout penalty. Comply with all local minimum working age laws andrequirements and not utilize child labor. Vendors maynot employ an individual under the age of 16 unlesssuch employment is allowed by,Vendor Code of ConductJanuary 2016 Not engage in physical discipline or abuse.Physical abuse or discipline, the threat of physicalabuse, sexual or other harassment and verbal abuseor other forms of intimidation is prohibited. We alsoexpect our vendors to communicate with allindividuals with civility and respect. Pay living wages under humane conditions. Allworkers shall be provided with clear, writteninformation about their employment conditions withrespect to wages before they enter employment andas needed throughout their term of employment.Deductions from wages as a disciplinary measureshall not be permitted unless permitted by national orapplicable local law. All disciplinary measures shouldbe recorded. Wages and benefits paid for a standardworking week must meet, at a minimum, national orapplicable local legal standards. Not require workers to work more than the maximumhours of daily labor set by national or applicable locallaws; ensure that overtime is voluntary and paid inaccordance with local laws and regulations. Maintain a healthy relationship with union employees,support the right to exercise freedom of association,and comply with the provisions expressed incollective bargaining agreements.10

Keep employee records in accordance with local andnational regulations. Maintain an internal process to allow employees toconfidentially and anonymously report allegations ofmistreatment, discrimination, abuse, violations of law,violations of this Vendor Code, or other ethicalviolations. Conduct a prompt and thorough investigation of anysuch report and take corrective action as necessaryand appropriate; and cooperate with JLL in any suchinvestigation and provide JLL with such informationas JLL may reasonably request. Not retaliate against any employee (or any JLLemployee) who reports in good faith any potentialviolation of this Vendor Code of Conduct.Sustainability PracticesJLL is determined to be a good corporate citizeneverywhere its people live and work. We recognize thatbuildings can have a significant impact on communities,the environment and on climate change, and that JLL canplay a meaningful role in addressing these challengesthrough our own operations and theadvice we give our clients about realestate development, investment andoccupancy. We aim to developleading standards and practices inour own offices and help our clientsdo the same. Everything we do today should be Buildinga Better Tomorrow. JLL expects its vendors to share its commitment tosustainability by meeting or exceeding therequirements of environmental laws and regulationsand promoting acceptable levels of energyconsumption, water use and waste management inorder to reduce the environmental impacts of ourbusiness operations and those of our clients. We expect our vendors to manage and reduce theirsocial impacts, to support their employees and thecommunities in which they operate.Vendor Code of ConductJanuary 2016The JLL Sustainability Commitment, together with otherinformation about our sustainability program, is includedwithin our Global Sustainability Report on our publicwebsite at ity-leadership.Ethical Treatment of AnimalsAs part of its commitment to engage in practices thatenhance the public’s welfare, JLL seeks to ensure theethical treatment of animals in all respects at the facilitiesthat JLL operates for itself as well as at the retail, office,and other properties it manages for clients. It is JLL’spolicy to attempt to avoid the exhibition, use and/or sale ofanimals at all of such properties. Where animals areinvolved at any of such properties for valid reasons, theymust be treated humanely and in compliance withapplicable animal welfare regulationsCompliance with this vendor codeIt is the responsibility of the vendor to ensure that itsrepresentatives understand and comply with this VendorCode and to inform its JLL contact (or a member of JLLmanagement) if the vendor knows, or has reason tobelieve, that a violation by it or its representatives mayhave occurred or may occur in the future. JLL vendorsare expected to self-monitor their compliance with thisVendor Code. In additionto any other rights JLL may have under its agreement withvendor, JLL may request the immediate removal of anyrepresentative who behaves in a manner that is unlawfulor inconsistent with the Code of Business Ethics, thisVendor Code of Conduct or any Company policy.11

Compliance with client codes of conductIn the situation where a vendor is hired by JLL on behalf ofa client, we also expect that the vendor will comply with allapplicable rules, policies, procedures or codes of conductmaintained by the client, including in the event they aremore restrictive than the provisions of this Vendor Code ofConduct. If you believe that a client rule conflicts withanything in this Vendor Code of Conduct and you areunsure of what to do as a result, you are expected to workwith your primary Company contact and the client in orderto resolve the situation in a mutually satisfactory manner.Audits of internal controls and operatingeffectiveness of service providersSubject to the terms of any specific contractual provisionsthat apply, we expect that each vendor JLL hires will makeavailable to us, upon request, a copy of any audit that hasbeen performed of the controls and/or operatingeffectiveness of the vendor as a service organization(such as a SSAE 16/ISAE 3402, formerly known as SAS70/FRAG 21/94, or similar report). In general, we alsoexpect each vendor to provide us with responses to ourreasonable requests for information about compliance withthis Vendor Code, including as part of an audit by JLL’sInternal Audit or Legal Services groups.Management accountability andresponsibilityBusiness continuity and crisismanagementJLL vendors must designate a representative from seniormanagement to be responsible for compliance with thisVendor Code. Each vendor’s senior management shallalso coordinate and oversee a training program, to theextent appropriate depending on the type of product orservice being provided, for its employees and managerswith respect to the processes and procedures necessaryto comply with this Vendor Code.Subject to the terms of any specific contractual provisionsthat apply, we expect that each vendorJLL hires will have adequate business continuity plans inplace to continue to provide its services toa reasonable degree in the aftermath of any kindof operational crisis, whether caused by a natural disaster,equipment malfunction, power failure, terrorist act, cyberattack, or so forth. Upon request by JLL, the vendor willdisclose in reasonable detail and discuss the elements ofits business continuity plans and its information securitysystems and controls.Vendor Code of ConductJanuary 201612

Cooperation with investigations;compliance auditsWe expect that each vendor JLL hires will cooperate withus in any investigation we or the vendor may beconducting into an allegation of inappropriate or unethicalbehavior involving either a JLL employee or an employeeof the vendor where the allegation involves JLL or a clientfor whom the vendor is providing products or services.JLL requires our vendors to represent in their contractstheir compliance with the principles of this Vendor Code.JLL may require a vendor to provide additional informationregarding the vendor’s compliance with this Vendor Code.In addition, JLLreserves the right to audit our vendors to determinecompliance with this Vendor Code and expects ourvendors to reasonably cooperate with any audit as acondition to continuing to work with JLL.No creation of third-party rightsThis Vendor Code does not confer, nor shall it be deemedto confer, any rights on the part of third-parties, includingany third-party beneficiary rights. For example, noemployees of any vendor shall have any rights againstJLL by virtue of this Vendor Code, nor shall suchemployees have any rights to cause JLL to enforce anyprovisions of this Vendor Code, the decision with respectto any such actions being reserved by JLL in its solediscretion.Reporting of questionable behavior or possible violationsWe expect each vendor to report timely to JLL any known violation of this Vendor Code. You are encouraged to raise anyquestionable business practice or compliance concern to your primary JLL contact. However, JLL recognizes that there maybe times when this is not possible or appropriate. In such instances, please contact any of the following:1. The JLL Global Ethics Helpline at: 1-877-540-5066 or log into www.jllethicsreports.com.The Helpline and the website are maintained by an independent service provider, areavailable at all hours of the day and night, and may be used in all major languages.Reports made to the Helpline or the website are sent to the Company’s Global GeneralCounsel for further investigation.2. Email the JLL Ethics Officers at: Ethics.Officers@jll.com.3. Send a letter to the Global General Counsel and Chief Ethics Officer at: JLLIncorporated, 200 East Randolph Drive, Chicago, Illinois USA 60601.4. If the violation pertains to human trafficking, in addition to the above you may contact the Global Human TraffickingHotline at 1.844.888.FREE or its email address at help@befree.org.JLL will not tolerate any retribution or retaliation taken against any individual who has in good faith sought out advice or hasreported questionable behavior or a possible violation.We thank you for your compliance with this important Policy and look forward to a mutually beneficial relationship with all ofour vendors based on the highest levels of ethical behavior.Vendor Code of ConductJanuary 201613

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Modern Slavery Act 2015. Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking. We have a zero-tolerance approach to modern slavery and we are committed to implementing and enforcing effecti