jll.com

Modern Slavery
Statement2024

Modern Slavery Statement | 2024

About JLL
Introduction

Our operations

Jones Lang LaSalle Incorporated and its subsidiaries (“JLL”)
approve and issue this joint Modern Slavery Statement (this“Statement”) under the UK Modern Slavery Act, the AustralianModern Slavery Act, the German Supply Chain Due Diligence
Act, and the Canadian Fighting Against Forced Labour andChild Labour in Supply Chains Act (collectively, the “Acts”
and individually, the “Act”).

We deliver an array of real estate services across fourglobal business lines – Markets Advisory, Capital Markets,
Work Dynamics, and JLL Technologies – and we manage
our investment management business globally as LaSalle
Investment Management (“LaSalle”).

This Statement complies with JLL’s UK, Australian, German,
and Canadian businesses’ reporting obligations under therespective Acts, but our responsibilities and commitments
to manage our exposure to the risks of modern slavery andhuman trafficking apply in our operations and supply chains
across all our global businesses. This Statement covers thereporting period of January 1, 2023, to December 31, 2023.

We leverage the strength of this global full-service platform toprovide the best capabilities to our clients locally, regionally,
and globally, including:• Leasing: representation of landlords and tenants for realestate leases• Capital markets: representation of sellers and buyers in thesale and purchase of real estate on behalf of clients• Integrated property and facility management: ensuring theefficient and proper operation of real estate assets

Who we are• Project and Development Services: consultation,
management, design and build

For over 200 years, JLL (NYSE: JLL), a leading global
commercial real estate and investment managementcompany, has helped clients buy, build, occupy, manage andinvest in a variety of commercial, industrial, hotel, residential
and retail properties. A Fortune 500 company with annual
revenue of $20.8 billion and operations in over 80 countries
around the world, our more than 106,000 employees bring
the power of a global platform combined with local expertise.
Driven by our purpose to shape the future of real estate fora better world, we help our clients, people and communities
SEE A BRIGHTER WAYSM. JLL is the brand name, and aregistered trademark, of Jones Lang LaSalle Incorporated.
For further information, visit ir.jll.com.

• Advisory2• Consulting and research• Real estate valuation• Technology• Sustainability
Through LaSalle, which is one of the world’s largest and mostdiversified real estate investment management companies,
we provide clients with a broad range of real estate investment
products and services in private and public capital markets.

Modern Slavery Statement | 2024

Our supply chains
The specialized nature of commercial property services
requires us to deliver a variety of services through long(and often multi-tiered) supply chains.
We have over 70,000 supply partners worldwide in over 80
countries and manage spend of approximately $12.6 billion

annually across our corporate operations and on behalfof clients. Our most complex supply chains exist in ourIntegrated Property & Facilities Management, Project &Development Services, and Property & Asset Managementbusiness segments.

The types of goods and services we procure for ourbusiness are:

The types of goods and services we procure for ourclients are:

• Information technology goods and services(hardware, software, servers, consultants)• Property/facility management services (food andhospitality, HVAC, janitorial, landscaping, office services,pest control, security, UPS maintenance, transportation,water treatment, workplace strategy, fire/life/safety,
technology services, electrical/ mechanical, plumbing/hydraulics, kitchen/ bathroom consumables)• Professional services (lawyers, accountants,
consultants, auditors, recruiters, financial advisors,market intelligence, data)• Office goods and services (stationery, food and drink),
travel services, property/facility management services(food and hospitality, HVAC, janitorial, landscaping,office services, pest control, security, UPS maintenance,transportation, water treatment, workplace strategy,
fire/ health and safety, technology services,
electrical/mechanical, plumbing/ hydraulics,
kitchen/bathroom consumables)• Project and Development Services (consultation,
management, design and build)• Project management and consultation: construction anddevelopment projects (construction/fit-out, architecture,engineering, environmental services)• Research• Marketing• Consulting services• Design, build and fit-out services• Financial services (insurers, banking)We include modern slavery contractual obligations for our
supply partners, including a commitment to abide by our
global Human Rights Policy, which prohibits violations ofhuman rights anywhere in our operations or our supply chains,3

and our Vendor Code of Conduct, which requires our supply
partners to comply with modern slavery laws and refrainfrom engaging in modern slavery, forced labor, and humantrafficking.

Modern Slavery Statement | 2024

Modern slavery risks
JLL is committed to maintaining the highest ethical standards
and engaging in practices that enhance the welfare, safety,
and well-being of our employees, business partners, and wider
communities across the world. Like any large organizationthat operates across geographical borders and has complex
supply chains, we must work hard to overcome challenges toensure that these standards are upheld across every facet ofour business. This Statement identifies the key modern slavery
challenges we inherently face as an organization.
We regularly review our operations and supply chains tounderstand modern slavery risks associated with them.
As part of this review, we consider sector and industry risk,
products and services risk, geographic risk, and entity risk.

Areas of vulnerability identified in our operations include:
Sector and industry risk:
JLL encounters risk through the supply partners we hire to provide property management and construction services to ourclients, who may employ people just starting in the labor market, without higher education, on entry-level wages, or who
are otherwise vulnerable. We recognize that some products our supply partners or we procure to provide services may
also pose a modern slavery risk, such as office consumables (coffee, paper products, and fresh fruit), personal protective
equipment (PPE), manufactured components of office furniture/furnishings, and technology equipment.
Products and services risk:
JLL, like others in our industry, has high supply partner spending in five key sectors where modern slavery is prevalent:construction, janitorial, landscaping and ground maintenance, hospitality, and security services. Products such as
solar panels, which we may procure for the sustainability services we provide, pose additional risks, as do technology
components made from forced labor, which may find their way into the technology products JLL develops and technology
solutions JLL provides to clients. Having a supply chain that operates in these areas increases our inherent exposure toservices provided or products made using forced labor as well as to certain operators who are becoming more clandestinein their approach as governments and other large organizations increasingly condemn modern slavery practices.
Geographic risk:
JLL operates in more than 80 countries, including in regions where there is geopolitical tension or in countries identified
in the Global Slavery Index as having a higher prevalence of modern slavery in their populations. Additionally, we provide
services in countries where the Global Slavery Index indicates there is little to no government action to address modern
slavery; and/or identifies a weak government response to modern slavery.
Operating in such environments poses a challenge, as we may inadvertently engage with supply partners in locations
where modern slavery activities are commonplace, or unregulated by the authorities. We continue to promote businesspractices that protect the most vulnerable in society as we work with clients and supply partners to increase awarenessand implement controls to mitigate risk.
Entity risk:
The nature of our services means we have complex supply chains, which inherently exposes us to third-party conduct risk.
We strive to reduce this exposure through training our supply chain employees and other diligence activities.
4Modern Slavery Statement | 2024

Actions to assess and address
modern slavery risks
In 2023, we continued to strengthen the management ofour program and to increase education and awareness by
expanding the reach of the Modern Slavery Express Training
we developed in 2022, engaging cross-functionally, andincorporating requirements and activities developed in
response to the German and Canadian Acts.

Effective management
The JLL Modern Slavery Committee (“Committee”) continued
to expand its membership and meet throughout 2023.
The Committee includes members of our Ethics & Compliancefunction, Sourcing & Procurement, Human Resources, and ourhigher-risk business segments (Integrated Property & Facilities
Management, Project & Development Services, Property &Asset Management, and Tétris).

These actions directed employees to our dedicatedModern Slavery intranet site, which includes various
resources and training.

Education and awarenessEducation and awareness for our employees and supply
partners are essential to help combat modern slavery.
Tailored training increases the level of industry-specificunderstanding of the issue, while providing clear reporting
processes for anyone who suspects an incident. Due to thegeographic diversity of our business, we focus on ensuringthat our employees are aware of the devastating impact
modern slavery has on individuals and communities,
and how they can support our battle against modern slavery,
regardless of local customs.

Our modern slavery incident management process gives clear
direction to our employees about how to identify and reportsuspected instances of modern slavery in the workplace.

Employee training

Building awareness of our program and our annual Statementwith our colleagues across the world remained a key activity
throughout the year.

Across these functions we nearly doubled the number of
employees in the pilot group who completed our 90-second
Modern Slavery Express Training, reaching over 15,000
employees through our learning management system.
A further 500 employees completed one of our longer modern
slavery training modules. Most employees completing
modern slavery training were in our Work Dynamics businessline, which includes business segments at higher risk formodern slavery activities (e.g., Integrated Property & Facilities
Management, Sourcing & Procurement), our Markets Advisorybusiness line, and our Human Resources corporate function.

Actions included:• Communications to our Legal & Compliance teams andour global network of Ethics Liaisons for distribution tobusiness lines• Communication of toolkits and resources to help managers
inform their teams and clients about our program• Communications across regional, local, and business-line
channels to raise awareness of the risks of modern slavery• An all-company message to announce the publication of
our Statement
5

In 2023, we continued to concentrate on delivering our modern
slavery training to our employees in higher-risk functions.

Modern Slavery Statement | 2024

We also targeted our Human Resources and Marketing
teams in Australia for education on our program,including how they can promote and assist with its
implementation and development. The education included
information about JLL’s resources and where to find them;
introduced the modern slavery questionnaire for distribution
to HR and Marketing supply partners such as recruiters,
job placement platforms, background-check providers,
benefit providers and others; reminded the teams about our
90-second Modern Slavery Express Training and 15-minutetraining module (for employees and supply partners); andhighlighted the Incident Response Procedure and Ethics
Everywhere Helpline.

Ethics & Compliance awareness initiatives
We continued to promote our internal Ask Ethics tool (which
we converted to a Chatbot format to simplify and expediteuse) and our public-facing Ethics Everywhere Helpline in
2023, where employees and others can submit reports andquestions anonymously.
In addition, we updated and automated our databaseof standard responses to client and potential client
questionnaires, which increasingly include questions about
our approach to human rights issues and how we keep
modern slavery activities out of our operations and supply
chains. Employees use this database to provide clients
information about our program.
Ethics & Compliance completed a major update to JLL’s
Whistleblower and Non-Retaliation Policy to strengthen
understanding of our global process for reporting ethics
concerns, and JLL’s commitment to protection from retaliation.
In connection with the update, we developed Speak Up
Training to promote a speak-up culture across our businesses
and created a Speak Up Portal containing useful informationand materials. We improved our external JLL Ethics
Everywhere websites to provide clearer guidance to external
persons who may have potential whistleblower claims.
In certain EU countries, our external Ethics Everywherewebsites now contain a new one-page guide to ourWhistleblower and Non-Retaliation Policy and process,for transparency reasons.
6

In preparation for implementing the requirements of theGerman Supply Chain Due Diligence Act, our German Ethics& Compliance team issued a communication introducing thelaw and implementation of an initial supply partner evaluation
form to begin the risk analysis process.

Training for our supply partners
We continued to roll out our 90-second Modern Slavery
Express Training to our supply partners. The training covers thefundamentals of labor rights and modern slavery, red flags formodern slavery, and how to report an issue.
In its first-round rollout, we targeted supply partner employees
in countries that have English as a first or second language(Australia, Canada, India, Kenya, New Zealand, Philippines,
Singapore and the U.S.). To facilitate the rollout, we createdtemplates for our category managers to introduce the training
to their supply partners.
In late 2023, we started translating our supply partnertraining in five languages (Simplified and Traditional Chinese,
Japanese, Bahasa Indonesian, and Thai). We are working
on adding more translations in Spanish, Portuguese, Polish,
French, Arabic, Italian, German, and Malay in 2024.
We use multiple platforms to deliver this training to caterto the needs of particular businesses. Some deliver the
training via JLL’s own ‘Onsite’ platform, developed to manage
health, safety, and site compliance issues. Our Property &Asset Management (PAM) business in Australia delivers thetraining by Cm3, which workers must complete before theycome to a JLL-managed site. This enables the PAM business
to obtain 100% completion by all supply partner workers(24,530 workers in 2023). We also created a version of themodule in QuestionPro so that all supply partners havedirect online access.
We plan to offer further supply partner modern slavery training
globally via QuestionPro in 2024, as it affords uniform and easy
access and does not depend on supply partners having accessto a JLL system.

Modern Slavery Statement | 2024

Supply partner engagement
Sourcing & Procurement’s 2023 Global ESG Strategy included
modern slavery as one of five focus areas. As a part of thisstrategy, our modern slavery activities in the supply chain
centered on delivering compliance and managing risk in our
supply chain around modern slavery, while leveraging thefoundational efforts from our Ethics & Compliance team.
Key initiatives in 2023 included:
1. Defining JLL’s ESG requirements for supply partners, suchas asking supply partners to commit to having their own
modern slavery statement
2. Issuing an ESG request for information to help JLL establish
a baseline to identify where supply partners are on theirmodern slavery journeys and to place supply partners in
JLL’s modern slavery maturity model
3. Developing and agreeing ESG roadmaps with supply
partners, including setting success metrics such as 100%
completion of JLL’s Modern Slavery Express Training

Client awarenessWe updated our modern slavery awareness material for
deployment in our client sites and made it available on our
intranet site. We can co-brand the collateral provided toclients to demonstrate our partnership in our ongoing efforts
to mitigate the risk of modern slavery within our businessand through our supply chains, as well as to promote ethicalconduct in the workplace. Clients also have options to add
other details, such as their own helpline information.

Partnering with our clients
In December 2023, our compliance team for one of our largest
accounts recognized United Nations International Day for the
Abolition of Slavery, partnering with the client to hang posters
and email the entire supply chain with the goal of raisingawareness of red flags and how to report concerns.

Due diligence• Our business lines and Sourcing & Procurement
professionals continue to improve their understanding of7

the risks of modern slavery. That increase in knowledge
has made it easier to implement processes to identify andmitigate the risks of modern slavery activities in our supply
chains. By being able to identify red flags early, we seek
to avoid engaging with questionable prospective supply
partners. In the case of existing supply partners, we workwith them to remediate their practices and mitigate thefinancial impact on vulnerable populations that resultsfrom measures taken to eliminate questionable practices.
If efforts to remediate are not possible, we terminate
their services.
• In 2023, our Sourcing & Procurement team developed
globally applicable modern slavery due diligence questions,building on existing questions at the regional level.
These will launch as part of the global deployment of
JLL’s new Supplier Portal powered by Aravo. The rollout
will begin in 2024 with a focus on our Work Dynamics
business line, starting with the US, Australia, and UK.
Additional countries will follow.
• In 2023, we continued to direct our businesses to include
clauses in our supply partner contracts requiring our supply
partners to comply with our Vendor Code of Conduct,
which prohibits engaging in any of the activities comprisingmodern slavery.
• We used Sphera Supply Chain Risk Management software(previously “riskmethods”), containing 5,885 of JLL’s
worldwide high-use supply partners and clients to monitor
numerous issues, including human rights.
• We initiated a partnership in December 2023 with Integrity
Next, a leading solution for supply chain sustainability
management to enhance our ESG supply chain efforts
including modern slavery.
• JLL remains aware of the risk of contributing to lossof income for vulnerable families due to our efforts toeliminate modern slavery, forced labor or child laborin our supply chains and across business lines. To date,
we have neither observed nor received any reports of aloss of income as a result of the trainings, methods,
reporting, or steps we have put in place internally orwith our supply partners.

Modern Slavery Statement | 2024

Complying with new legislation
Building on the preparations started in 2022,
JLL’s German business is well into implementationof the German Supply Chain Due Diligence Act (LkSG),
aligning German requirements with our firm-wide
Modern Slavery program. We developed a questionnaire
and training video for core direct supply partners intheir corporate and IFM business and will use thequestionnaire to categorize high-risk supply partners
and develop monitoring and contracting strategies.
There is an awareness-raising campaign that the teamis supplementing with training modules and otherresources to reinforce what employees should look for
and what we can do if we spot red flags.

In 2023, JLL’s Canadian Legal & Compliance teaminitiated a compliance review of policy and procedurein advance of Canada’s rollout of new modern slavery
legislation. Working with Human Resources andProcurement, the team will develop a campaign in 2024
that includes initiating mandatory reporting under the
Act in Canada and targeted mandatory modern slavery
awareness training (on forced labor and child labor) toemployees in higher-risk business lines.

Strengthening supply partner relationships
JLL continues to improve its bespoke modern
slavery compliance program for a large Australian
government business enterprise’s supply chain since
first implementing a modern slavery framework for theaccount in 2021.
Approach
As part of the annual program, new and existing supply
partners that JLL manages on behalf of the client must
indicate if their organization has either a modern slavery
policy or a modern slavery statement.
In 2023, the program included more than 400 supply
partners. Through the program we identified that many
supply partners were unaware of modern slavery so
our Sourcing & Procurement team used this as anopportunity to provide information as well as to sharea modern slavery policy template that supply partners
could adapt to their business circumstances.

8

For supply partners that did not want to adopt a policy,
JLL conducted a risk assessment to identify the risk ofmodern slavery (low, medium, and high). JLL maintains
the authority to remove or suspend a supply partner
without client endorsement if we believe they are notcompliant or pose a risk.
The JLL account stores all supply partner compliancedocumentation centrally and makes it accessible to both
JLL and the client to enable both parties to efficiently
monitor and analyze supply partner compliance statistics.
We commenced a new cycle of the program in
December 2023 with improvements made to data
capture technology to make it easier for supply partners
to respond to inquiries.
OutcomeJLL achieved 100% compliance across the JLL-managedsupply partners.

Modern Slavery Statement | 2024

Risk assessments and audits• As they have done annually since 2019, one of our largest
accounts performed a minimum wage and modern slavery
compliance review in 2023, completing 890 checksof 27 supply partners across our Asia Pacific, EMEA,
and Americas regions. The team uses the review to confirm
there are procedures and controls in place and operating as
intended to help ensure supply partners achieve minimum
wage requirements promptly, pass Change Control Noticeminimum wage increases fully and timely to the intended
recipients, and comply with local labor laws. In addition,
the team conducted supply partner surveys and searched
for signs of modern slavery issues. Overall, the review
showed 98% compliance, identifying zero critical or highrisks. The team identified a few isolated issues that they
addressed with the supply partners, and in many cases,
remediation is already complete.
• JLL used this review framework to partner with anothermajor client, selecting one supply partner from each of
five potentially high-risk countries in Africa and the Middle
East for the initial review. The team sent supply partners
a survey to complete and then scheduled meetings witheach to review (where applicable) the Code of Ethics,
conduct pay slip checks (payment of minimum wage
and taxes where applicable), and review passportmanagement, right to work (visas) and laboraccommodation. Some actions resulted from the review,
all of which the JLL team remediated. Actions included
improving transportation safety due to conflicts in local
regions, remediating minor health and safety findings
at labor accommodation, reviewing pension and healthcontractual requirements, and providing pay slips to
employees receiving payments via telephone transfer.
• The compliance team for a large client completed an
external audit focusing on modern slavery issues andhuman rights risks across the organization, including
reviewing their supply chain. The review assessed ourprogram and the associated governance, including
by conducting on-site reviews to ensure employees
understood local practices including working hours,
remuneration, health and safety, and ethics.
9• In Asia Pacific in 2022 and early 2023, Sourcing &Procurement completed supply chain reports for 14
of our client accounts. A component of these reports
involved conducting desktop searches for supply partners
to identify any possible incidents of modern slavery.
Through this search, JLL identified one alleged incident
and escalated the case through to our Ethics & Complianceteam for further investigation and action.

Policies and procedures
Our Human Rights Policy sets out our commitment topromoting workers’ rights and fair labor practices and toeliminating modern slavery practices in our business andsupply chains. This commitment is reflected in our Code of
Ethics, Vendor Code of Conduct, and through our adoptionof the Responsible Business Alliance Code of Conduct.
We launched major revisions of our Code of Ethics (in 2022)
and Vendor Code of Conduct (in 2023), creating clearer,
simpler, and more engaging documents to foster greatercommitment and understanding for the diverse populations
in our operations and supply chains.
Our Whistleblower and Non-Retaliation Policy further
supports our efforts to encourage speaking up byaddressing the challenges of remediating illegal activities
while protecting victims.
Our Ethics Everywhere Helpline is a confidential reporting
platform available to our employees, contractors, clients,
supply partners, and members of the public if they have aconcern or suspect behaviors that are inconsistent with our
Code of Ethics and our policies or the law. It is confidential
and available 24 hours a day, 7 days a week, and reports canbe made anonymously. In 2023, we improved content on
the platform’s website and increased the number oflanguages available to include Polish, Italian, German,
Arabic, and Japanese.
Annually, all JLL employees are responsible for certifying thatthey have read, understood, and will follow our corporate
policies and the principles outlined in our Code of Ethics.
New hires sign the certification in accordance with their
onboarding process. The 2023 certification included
mandatory ethics and compliance training on select topics.
We plan to include in the 2024 mandatory training a modern
slavery module.

Modern Slavery Statement | 2024

Assessing our effectivenessWe believe in continuous improvement. With that approachin mind, we annually assess the effectiveness of our program
and look to identify opportunities to increase the impact of
our efforts.
The following activities help us determine whether our actions
to assess and address modern slavery risks are working:• Working closely with our Ethics & Compliance team,which includes modern slavery subject matter experts
and representatives for each geographic region who meet
regularly to review our global response to modern slavery
and the local implementation of our policies, procedures,risk assessments, and education and awareness programs• Reviewing and updating our policies, due diligenceprocedures, and risk assessment processes to reflect
the changing nature of our clients, locations, services,supply partners, and external factors such as geopoliticalrisk and changes in global financial markets• Quarterly meetings with our Committee, which includes
representatives from our higher-risk business lines
and functions• Regularly engaging with senior management from Work
Dynamics, Property & Asset Management, Sourcing &Procurement, Human Resources, and Legal & Compliance• Monitoring supply partner responses to modern slaveryquestions on the new Aravo Supplier Portal and throughour third-party platform, Integrity Next, which will help us
identify modern slavery risk by country and industry as we
implement the tool globally in 2024
• Tracking figures, including the number of employees whocompleted their Code of Ethics certification, number ofworkers who attended education sessions, number ofreports received through our Ethics Helpline and how they
were managed, and the number of supply partners thatcompleted our prequalification questionnaires and amberand red flags raised

Consultation
In accordance with JLL’s global commitment to minimizing therisk of modern slavery practices in our operations and supply
chains, our Ethics & Compliance team facilitated the review
and consultation of our modern slavery practices and thisStatement with representatives of the reporting entities andour higher-risk business segments and functions, including the10

Committee. The Statement was then reviewed and approvedby the global Board of Directors, as well as the Australian
Board of Directors, in accordance with the Australian Act,and the Canadian Board of Directors, in accordance with
the Canadian Act.

Modern Slavery Statement | 2024

Looking ahead
We will continue to work on raising awareness of modern
slavery as a human rights violation and evolve our internal
processes to be more consistent globally and aligned withbest practices.

As part of this, we will implement tailored education andtraining for specific, higher-risk business lines and geographies
while striving to work closely with more of our clients to alignexternal efforts.

Our focused activities for the next reporting period include:

1
3
5
7
11

Expanding the membership of our Committee
to representatives from more higher-riskbusiness segments and functions to increase
engagement and awarenessMonitoring supply partner responses tomodern slavery questions on the Aravo
Supplier Portal and Integrity Next

Monitoring changes in the legislative
landscape, adapting strategies andprocedures to meet evolving legal standards
and best practices, working with regulators
as needed, increasing collaboration withbusiness partners

Raising awareness of modern slavery andhow to spot red flags with our on-site andremote workers and our supply partners,
including exploring options for collaboratingwith our clients

2
4
6
8

Updating and delivering targeted modern
slavery training to our employees and our
supply partner employees, especially in ourhigher-risk business lines and functions

Expanding risk assessments of our internal
operations across all functions and regions,with deeper dives into higher-risk operations
or geographies

Ensuring our employees are aware of ourmodern slavery incident management
process, ethics reporting, speak-up portal anddatabase of standard responses to be able toidentify and escalate circumstances that may
indicate modern slavery activities

Capturing metrics about modern slavery in
our operations and supply chains, including
through our Aravo Supplier Portal, so that
we can have more useful conversations
about how we can improve our modern
slavery risk responses

jll.com

Board ofDirectors’ approval

Siddharth N. Mehta
Chairman of the Board

Christian Ulbrich
Global Chief Executive Officer

About JLL
For over 200 years, JLL (NYSE: JLL), a leading global commercial realestate and investment management company, has helped clientsbuy, build, occupy, manage and invest in a variety of commercial,industrial, hotel, residential and retail properties. A Fortune 500®
company with annual revenue of $20.8 billion and operations in over
80 countries around the world, our more than 106,000 employees
bring the power of a global platform combined with local expertise.
Driven by our purpose to shape the future of real estate for a betterworld, we help our clients, people and communities SEE A BRIGHTER
WAYSM. JLL is the brand name, and a registered trademark, of Jones
Lang LaSalle Incorporated. For further information, visit jll.com.