Cushman & Wakefield is committed to running our business responsibly and to the highest ethical standards. We are one of the leading real estate services firms in Luxembourg, with over 100 people working directly for us in 3 offices across Luxembourg. Our clients are in the public, private, and not-for profit sectors in Luxembourg and across the globe.
We have zero-tolerance to slavery and human trafficking, and Cushman & Wakefield policy prohibits all forms of forced or compulsory labour. It requires vendors/suppliers to maintain and promote fundamental human rights, where employment decisions are based on free choice without any coerced or prison labour, no use of physical punishment or threats of violence or other forms of physical, sexual, psychological or verbal abuse as a method of discipline or control.
In addition, our policy mandates the adherence to minimum employment age limits defined by law or regulation, and the prohibition of children performing work that exposes them to undue physical risks that can harm physical, mental, or emotional development or improperly interfere with their schooling needs.
Given the nature of its business, for Cushman & Wakefield the perceived risk is principally through our supply chain either in procuring services to run our business or to deliver services to clients. Those suppliers operate in numerous sectors such as building and construction, facilities management, finance, technology, travel, and utilities. We also work with other professionals, advisors and consultants, and contractors.
In those parts of our business where we assess or believe the potential risks of modern slavery to be higher, we use a number of measures to reduce the risk. This includes:
- the use of contractual clauses in supplier contracts requiring adherence to our policy standards,
- conducting due diligence on suppliers for red flags of slavery and human trafficking,
- the express or implied requirement on suppliers to notify of any breaches.
To date, we have not been aware of any instances of slavery and human trafficking in our business or supply chain. We maintain an external hotline where employees, clients and third parties can report suspected slavery or human trafficking in our business or supply chain.
In the event a report is received, we will act immediately and resolutely. This can include working with suppliers to remedy any breaches, but also instantly terminating contracts, reporting to law enforcement and other bodies as appropriate.
We routinely train and remind our staff (and where appropriate, suppliers) on their obligations under our Code of Conduct, Legal & Compliance policies. We have asked our Head of Risk & Compliance to work with other stakeholders in our business to develop a strategy and approach for training on modern slavery and human trafficking.
The overall sponsor for this programme is Sébastien Bequet, our Head of Luxembourg. The leadership at Cushman & Wakefield tasked the Legal, Risk & Compliance team to monitor compliance with our policies in this area. The Head of Risk & Compliance is required to report regularly to the leadership on compliance with our policies in this area.
This statement is made on behalf of Cushman & Wakefield’s entities in Luxembourg on slavery and human trafficking. The statement will be reviewed annually, and is signed on behalf of Cushman & Wakefield in Luxembourg.
Head of Luxembourg