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Vendor Code of Conduct

JLL Vendor Code of Conduct

Contents
Introduction

03

Who we are04

Why this Code04

What we believe in05

What we need from you

06

How we can help you

07

Speaking Up

07

Valuing people, communities
and the environment

08

Doing business with integrity

11

Safeguarding assets, informationand interests

15

Complying with applicablelaws and contracts

17

Glossary of terms

19

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JLL Vendor Code of Conduct

Introduction
At JLL, we recognize that you – our supply
partners – are core to our ability to deliverworld-class commercial real estate services.
Indeed, our growth over the years is due in alarge part to your contribution. In this Code,
we outline how we can continue working
together by ensuring you meet our ethicalexpectations and minimum environmental,social and governance standards.
Thank you for the work you do and theprofessional service you provide to JLL
and our clients.

Peter Downie
Executive Managing Director,
Work Dynamics, JLL

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JLL Vendor Code of Conduct

Who we are
For over 250 years we’ve been at the heart of real estate, bringing diverse thinking and perspectives to investors andbusinesses worldwide, guided by our purpose of shaping the future of real estate for a better world.
This purpose is central to everything we do - we use our insights to drive our clients’ businesses, support theirworkforces and help communities thrive. We use our skills, technology and data to power smarter and moresustainable buildings, and help our clients develop strategies and pursue investments that deliver long-term value
and sustainable growth.

Why this Code: purpose and scope
The JLL team goes beyond our employees - it extends
to all supply partners that help us to deliver on our
promise to our clients. We developed this Codefor you, our supply partners, to set out our businessconduct and ethical expectations of you as well
as your employees, agents and sub-contractors(collectively “supply partners”).

4

All supply partners must comply with this Code while
conducting business for or on behalf of JLL. Our
compliance expectations include implementing policies,
procedures and training as well as taking preventativeand remedial action to avoid and correct gaps.

JLL Vendor Code of Conduct

What we believe inThree core values shape our culture and define who we are: teamwork, ethics and excellence.
These values underpin our commitment to our clients, to our communities and to each other. They provide
direction for all we do.

We believe in teamwork – we collaborate in order to succeed.
Working as one team we achieve our common goals and share mutual successes. We unite acrosslocations and businesses to build world-class teams offering first-class service.
We believe in ethics – we act honestly and responsibly.
Ethical business practices guide our actions, define who we are and how we behave. We act withhonesty and integrity to build trust and foster inclusive, responsible and lasting relationships.
We believe in excellence – we strive to be exceptional.
We want to grow and do better for our clients and ourselves. That’s why we are committed
to excellence, and to always seeking new and innovative ways to achieve our goals.

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JLL Vendor Code of Conduct

What we need from you
Values, words, and actions build culture. At JLL, we embrace our values and hold ourselves to the highest standards
and expect our supply partners to adhere to the same standards. This means:
Valuing people, communities, andthe environment• Prioritizing health, safety and wellness•

Promoting diversity and inclusion and developing
worker capability•

Respecting human rights, and treating all people
with dignity, respect and fairness•

Operating sustainably and with care forthe environment

Doing business with integrity• Acting with integrity to avoid all forms of bribery
and corruption

Safeguarding assets, informationand interests• Protecting JLL’s and client’s physicaland intellectual property andmaintaining confidentiality•

Respecting individuals’ privacy rights andsafeguarding personal information•

Acting in the best interests of JLL and our clients•

Complying with all laws regarding politicalcontributions and lobbying

Complying with applicable laws and contracts• Obeying all applicable laws•

Cooperating with all investigations and/or auditscommenced by or on behalf of JLL or our client•

Competing fairly for JLL’s business•

Avoiding insider trading•

Notifying JLL of breaches of law or contract•

Complying with trade sanctions and export controls•

Obtaining and maintaining appropriate licenses•

Identifying, disclosing and managing conflictsof interest•

Understanding and adhering tocontractual obligations•

Minimizing the risk of money laundering andfinancial crime.

Complying with these JLL policies concerning
vendors and cited industry codes:• Responsible Business Alliance Code of Conduct•

6

JLL’s Global Sustainable Sourcing &Procurement Policy

JLL Vendor Code of Conduct

How we can help you
We work with you because we have faith in the goods/services you supply and in your integrity. But in business
we understand things are not always simple. If you have any concerns about this Code or would like to talk further
about our requirements, please contact your JLL representative. We want to work with you to have a mutually
beneficial relationship.

Speaking Up
If you have an ethics concern or suspect any violation of this Code, our policies, or the law, please speak up so that
we can take action to address the problem. We encourage you to work with your primary JLL contact to resolve any
concern, but If you are uncomfortable speaking directly with someone in JLL, you can call our Ethics Everywhere
Helpline or use our online reporting tool – both are managed by an independent company and enable you to raise
concerns confidentially. They are available 24/7 in more than 165 Ianguages and in most countries, you can choose
whether you want to remain anonymous.
JLL’s Whistleblower and Non Retaliation Policy details our commitment to transparency, how to report a suspected
matter, and the process we follow to manage a matter. JLL will not tolerate any retaliation against an individual who
raises a concern or reports a possible violation of this Code.

You must:• Ensure that your workers and other stakeholders
are aware that they may raise concerns andhow to raise them7

• Ensure that no one retaliates against your workers ifthey raise a concern or complaint, cooperate with aninvestigation or refuse to do something that violates
this Code or the law

JLL Vendor Code of Conduct

Valuing people, communities
and the environment
Health and safety
Health and safety are central to everything we do at JLL. There is no substitute for prioritizing the safety
and wellness of people and ensuring safe and healthy workplaces.

You must:••

Follow all JLL and client health and safety policies,
rules and obligations (including JLL’s Global Health,
Safety and Environment Policy), and comply with allapplicable health and safety laws

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Investigate immediately and notify JLL of allincidents on a JLL or client site that result in severeor serious injury, death or environmental damage•

Implement procedures to correct circumstancesthat led to severe or serious injury, death orenvironmental damage on a JLL or client site•

Ensure your workers are appropriately skilled,licensed and trained to deliver services or goods
safely, and provide JLL with appropriate evidence
upon request

Complete a competent hazard and risk identificationassessment for the relevant site before providing
services or delivering goods to JLL or our client••

Develop and implement processes and procedures
to ensure that you deliver all services or goods in amanner that does not expose any person or property
to personal injury, death or property damage

JLL Vendor Code of Conduct

Diversity, equity and inclusion
We believe a diverse and inclusive culture is one where everyone succeeds. That’s why we’re committed to creating aculture of belonging where we welcome everyone and respect and value all individuals. Treating everyone with respect
and in a non-discriminatory way is an important part of our own Code of Ethics and we expect our supply partners toshare this commitment.

You must:•

Not discriminate against any person within yourworkforce, or anyone you work with•

Comply with all legislative requirements relating todiscrimination•

Treat people with kindness, courtesy and politeness•

Offer equal opportunities and make hiring decisions
that fully comply with employment law

9•

Embrace inclusivity and champion broad
perspectives to improve the relationships
you have with all stakeholders•

Explore business opportunities to engage anddevelop commercial relationships with small
businesses, local businesses and diverse vendors
in your supply chain

JLL Vendor Code of Conduct

Human rights and forced labor
JLL is a strong advocate for human rights as laid down in The Universal Declaration of Human Rights. We respect andprotect human rights for everyone without discrimination. We will not tolerate human rights violations of any kind in
our operations or supply chain.

You must:•

Comply with our Human Rights Policy;•

Ensure you:•

Are capable of identifying ethical and humanrights violations•

Investigate any potential human rights violations
in a timely manner•

Immediately correct any substantiated humanrights violations•

Keep JLL fully apprised of all potential andsubstantiated human rights violations•

Do not employ children, and obtain JLL’s priorconsent before engaging any person under theage of 16•

Do not permit forced labor of any type (including
modern slavery, prison labor, bonded labor, andindentured labor) in your operations and all tiersof your supply chain•

Are willing and able to respond to JLL requests
for information to complete our legislative
disclosure requirements

Working conditions
It is important that we treat all people fairly and with respect and dignity while at work. You must investigate any
allegation of inappropriate behavior or a breach of labor laws and take appropriate action.

You must:•

Ensure that your workers treat others in a
professional, respectful and fair manner•

Implement policies and procedures to identify
and protect workers from harassment, bullying
and intimidation

10•

Comply with minimum legislative requirements
on pay and wages, time off (including for illness/disability and vacation), maximum working hours
and rest periods, employment conditions andtermination of employment•

Permit, and in no way restrict, the freedom of
workers to join, not join or leave a union orworker association

JLL Vendor Code of Conduct

Sustainable procurement
To help achieve our purpose, we partner with our stakeholders to drive impactful and sustainable change. We do this byembedding sustainability into everything we do. As a JLL supply partner, we expect you to contribute to all relevant JLL
and client initiatives aimed at managing sustainability risk and improving sustainability performance. If you are unsure
how you can improve your sustainability practices, please contact us.

You must:•

Comply with applicable environmental
sustainability laws•

Handle and dispose of hazardous wastematerials responsibly•

Actively reduce the carbon footprint of yourproducts or services, and provide energy andresource efficient options•

Report, upon request, data relevant to
JLL’s Science Based Targets•

Set your own sustainability or carbon
emission reduction goals•

Demonstrate the climate resilience of youroperations, goods, and services•

Reduce waste and the lifecycle impacts ofyour product or service

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JLL Vendor Code of Conduct

Doing business with integrity
Avoiding bribery and corruption
We do not give or accept bribes in any circumstances, anywhere we operate. There are no exceptions, regardless of
local culture or market practice. Bribery harms our clients and business partners, undermines trust in the marketplace,and damages our communities.

You must:•

Not promise, offer or pay anything of value (including
gifts, hospitality, charitable donations, travel or
employment) to anyone (including a JLL employee,client, supply partner or government official) to
influence the other party’s action or decision in orderto promote JLL’s business interests or to gain any
unfair advantage•

Implement effective policies and procedures toprevent actual or the perception of bribery andcorruption (including policies against offering or
accepting kickbacks or other incentives to securebusiness or influence a decision)•

Comply with all applicable anti-corruption laws
wherever you do business12•

Not make “facilitation” payments (also known as“kickbacks” or “grease payments”) to speed up
government processes or secure government work,
even if this is considered normal business practice•

Perform due diligence checks on third parties you
work with to ensure you work only with business
partners who do not engage in bribery or corruption•

Not agree to hidden arrangements, commissions,
fees or rebates intended to secure business or
influence a decision or provide an unfair
business advantage•

Immediately report to JLL if someone offers orasks you for a bribe

JLL Vendor Code of Conduct

Competing fairly
We deal fairly with our customers, supply partners, competitors and employees and expect our supply partners to do
the same. This includes respecting competitive bidding processes and avoiding arrangements that limit competition,such as collaborating with competitors on pricing or market allocation.

You must:•

Comply with applicable antitrust and faircompetition laws•

Deal fairly with JLL and our clients, as well as withyour suppliers, competitors, and employees•

Refrain from manipulation, concealment,
disparagement, abuse of privileged information,
misrepresentation of material facts or any otherunfair practice to take advantage of others••

Respect competitive bidding processes•

Respect others’ confidentiality and intellectual
property rights, and seek authorization before using
confidential information belonging to a competitor
or third party•

Not use JLL or client confidential information or
intellectual property for non-JLL purposes•

Respect confidentiality, even when you are no longer
a JLL supply partner.

Engage only in accurate and truthful marketing
and advertising

Confidentiality
During the course of your relationship with JLL and our clients, you will receive information that may be commerciallysensitive or not publicly available. That information may extend to the existence of a transaction, the parties involved inthat transaction, and the timeframes related to that transaction. It is critical that you maintain the confidentiality of any
such information.

You must:•

Implement policies and procedures to identify andmaintain the confidentiality of information•

Immediately notify JLL or the client if you suspect anunauthorized disclosure of confidential information•

Only disclose confidential information:•

Respect the intellectual property rights andconfidential information of others, and not use
third-party confidential information or copyrighted
materials such as software, source code, leasing
information or images without authorization•

Not use JLL or client assets, resources or confidential
information for personal activities or gain•

Not identify a company as a client of JLL unless you
are authorized to do so and not share confidential
information about our clients or JLL on social media•

To people within your organization with a needto know the information, and only after they
have signed a Non-Disclosure Agreement•

To third parties if legally compelled, provided
that you first notify JLL and give JLL areasonable opportunity to respond orchallenge the request for disclosure•

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That you can establish was in your possession,or later entered your possession, through nobreach of your confidentiality obligations

JLL Vendor Code of Conduct

Economic sanctions and trade restrictions
It is important to comply with local and international trade controls, economic sanctions and embargoes that prohibit
doing business with certain countries, governments, entities, and individuals. Some laws and regulations also govern
how we can distribute services and technology across borders and use them internationally.

You must:• Review all business opportunities to ensurecompliance with trade restrictions, particularly
when a transaction involves providing services ortechnology across international borders• Avoid business with any country, government, entity,organization or individual where sanctions or trade
restrictions prohibit doing so• Complete a thorough due diligence review (including
sanctions screening) of your clients and vendors
before entering into a new business relationship andat regular intervals during a business relationship
Gifts and entertainment
Use good judgement when exchanging business courtesies. Gifts and entertainment can be viewed as bribes,
depending on the recipient, the nature and amount of the gift or entertainment, why you’re giving it and when
you’re giving it.

You must:• Comply with gift and entertainment laws of thejurisdictions where you do business• Never offer gifts or entertainment to government
officials or their employees for or on JLL’s behalf• Avoid gifts and entertainment that create afeeling of obligation or appear to be a bribe orconflict of interest• Avoid gift or entertainment items, activities or venues
that could be viewed as distasteful or offensive• Avoid giving or offering gifts or entertainment to any
JLL employee or representative that exceeds modest
value or JLL limits or violates this Code14

• Never ask for gifts or entertainment from business
partners, and never ask someone to offer a gift orentertainment on behalf of JLL or our client

JLL Vendor Code of Conduct

Insider trading
While working with JLL, you may become aware of material information about JLL, our clients or other companies
we do business with that is not known to the public (“material non-public information”), such as details of mergers or
acquisitions, unannounced changes in executive leadership, strategic business plans and outcomes of lawsuits or the
threat of a lawsuit. Sharing material non-public information with anyone may violate insider trading laws.

You must:• Contact JLL (on JLLInvestorRelations@jll.com) if you
have queries regarding what is or is not material
non-public information• Ensure none of your organization’s employees
or associates uses or shares material non-public
information for financial or other personal benefit• Keep material non-public information secure and not
discuss or share it with anyone else, including a partner,family member, friend or broker• Report immediately to JLL if you suspect or know thatanyone in or associated with your organization has usedmaterial non-public information for financial or otherpersonal benefit

Money laundering and financial crime
We do not wish to be associated with anyone involved in any financial crime, including money laundering, terrorist
financing or tax evasion, and we will report suspicious transactions to the relevant authorities. Accordingly, we expect
our supply partners to act responsibly to minimize the risk of money laundering across our operations.

You must:• Never knowingly participate in, or facilitate, money
laundering or financial crime of any kind
• Have due diligence policies and processes in place toknow your material business partners and reduce thechance that you, JLL, or the client will inadvertently
assist in money laundering• Conduct your business transactions with integrity,transparency and accountability to protect JLL’s andour clients’ reputations• Refresh due diligence checks if there is a change in
one of the parties to a transaction

15• Immediately report to JLL anything suspicious thatmight indicate that a person or business partner isinvolved in money laundering or a financial crime• Prepare timely, accurate and complete
financial records• Follow and comply with generally accepted
accounting standards and principles• Never agree to “off-the-book” arrangements• Act transparently in engagements with JLL and ourclients, and ensure documents and records accuratelyreflect the actual economics of a transaction

JLL Vendor Code of Conduct

Safeguarding JLL assets,
information and interests
Privacy and information security
Our clients, business partners and employees trust that we handle their personal information and data responsibly
and in accordance with applicable privacy and information security laws. You must safeguard all personal information
shared with you and respect individual privacy rights. Remember that your privacy responsibilities include physical andelectronic data, soft and hard copy documents, emails and messages.

You must:• Collect and use personal information only as needed
to fulfil your legitimate business and legal obligations• Comply with JLL Data Protection Addendum if
you process personal information on JLL’s behalf,
unless JLL agrees in writing to using other dataprotection protocols• Honor privacy choices and use personal information
only for the purposes communicated and intended• Minimize and anonymize personal information where
feasible and retain it no longer than necessary

16• Implement appropriate technical and organizational
measures to protect against personal information anddata loss and use systems and email responsibly• Secure physical and electronic data by using strong
passwords and never share them with others• Understand and follow JLL’s privacy, information
security and data breach policies and procedures• Share and provide access only to those who need theinformation to do their job• Immediately report any suspected andactual data breachJLL Vendor Code of Conduct

Conflicts of interest
We believe that it is vital for all organizations to establish a framework to proactively identify, disclose, and manage
conflicting interests to avoid problems. A failure to identify or disclose conflicts may breach law or professional
standards, and potentially damage people’s trust in JLL, jeopardizing existing and future business opportunities andundermining our values.

You must:• Avoid situations where any conflict of interest,
whether involving your organization or your workers,
might influence or appear to influence decisions• Act in the best interests of JLL and our clients anddisclose to JLL all potential and actual conflicts assoon as possible• Manage potential conflicts transparently andcarefully, and in accordance with JLL’s requirements• Maintain an up-to-date record of any disclosures andactions agreed

Representing JLL
Because you are a JLL supply partner, third parties may view you as representing JLL. Accordingly, you and yourworkers must at all times act in JLL’s and our clients’ best interests. Importantly, this involves understanding our
relevant strategic goals and priorities and delivering goods or services in a way that promotes those objectives.
Additionally, as JLL’s representative, it is important that your workers do not behave in a manner that may damage
JLL’s or our clients’ reputations.
If for some reason you are unable to act in JLL’s or our clients’ best interests, you must notify us immediately.

You must:• Implement procedures and processes to ensure yourworkers, while working for JLL or our client:• Do not work while intoxicated• Do not possess or have control over a firearmor other weapon, unless previously agreed
by JLL in writing• Do not engage in any behavior that is violent,
aggressive, intimidating or harassing• Conduct careful due diligence to ensure you source
goods and services from responsible third parties• Ensure that any third parties you engage to assist in
supplying or delivering goods or services to JLL or ourclient comply with this Code• Monitor the performance of all third parties you
engage to assist in supplying or delivering goods orservices to JLL or our client and, where needed, takecorrective action

Political contributions and lobbying activities
We expect you to comply with all laws concerning political contributions and lobbying activities and not make politicalcontributions or donations in JLL’s name.
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JLL Vendor Code of Conduct

Complying with applicable laws
and contracts
EthicsOur commitment to ethical conduct underpins everything we do at JLL. We maintain our commitment to ethics
through our Ethics Everywhere program, and we demand the same commitment and conduct from our supply
partners. You play an important role in enhancing and safeguarding our ethical culture.

You must:• Promptly document and escalate to JLL all ethics
violations or concerns via our online ethics platform(Ethics Point) or JLL’s Ethics Everywhere Helpline(+18775405066)• Foster a culture of trust, integrity and honesty inyour organization• Cooperate with any ethics investigation JLL
or our client undertakes• Promote high standards of animal welfare wheneveranimals are brought into or housed on JLL or client
premises, and ensure they are treated humanely andin compliance with animal welfare regulations• Help your workers understand that living our ethicalvalues and doing business the right way are the only
ways to achieve successBusiness continuity and crisis management
You are key to the services JLL provides our clients. To ensure we are able to fulfill our commitment to clients, we
expect our supply partners to have adequate business continuity plans in place to facilitate continuous service in theaftermath of an operational crisis, such as natural disasters, equipment malfunctions, power failures, terrorist acts,
cyber-attacks, etc. At JLL’s request, you must disclose the elements of your business continuity plans and information
security systems and controls in reasonable detail.

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JLL Vendor Code of Conduct

Audits and inspections
While we expect our supply partners to self-monitor and demonstrate their compliance with this Code, we or our client
may conduct inspections or audits to confirm compliance. This may include on-site inspection of your facilities orreviewing information and evidence including books, records, certifications, permits, and other documentation. Supply
partners who behave in a manner that is unlawful or inconsistent with this Code or JLL policy risk termination of theirbusiness relationship with JLL and/or our clients.

You must:• Cooperate fully with all audits and inspections,
whether conducted by JLL, our client or a third-party
representative of either JLL or the client• Not present information in a manner thatmisrepresents the truth• Not destroy, hide or fail to disclose key information

Organizational and worker capability
The success of this Code depends on you and your people possessing capability to deliver on our expectations.
Standards and best practices continually evolve, and we expect that you continually educate and train yourworkers on key topics.

You must:• Ensure all your workers are aware of, andappropriately trained on, the obligations
described in this Code• Ensure workers have appropriate qualifications
and licenses at all times, and only perform services
aligned with those qualifications and licenses• Build worker capability through informal andformal training• Supervise all work your workers perform on JLL
or client sites

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JLL Vendor Code of Conduct

Glossary of terms
Antitrust and competition laws
Antitrust laws (also referred to as competition, cartel
or monopoly laws) aim to promote healthy and faircompetition and prohibit competitors from agreeing
on pricing, carving up markets and engaging in othermarket abuse. These laws protect consumers frompredatory business practices and ensure that faircompetition exists in an open-market economy.
Bribery
Bribery is the act of offering, giving, promising, asking,agreeing, receiving or soliciting something of value forthe purpose of influencing an action.
Confidential information
Confidential information is any information that is not
publicly known and should not be disclosed to the
public. It includes proprietary business information,
non-public financial information, client and supplierlists, business plans and projections, government
service-related dataand personal health data.
Conflict of Interest
A conflict of interest occurs when a person ororganization has competing interests or loyalties
because of their duties to more than one personor organization. Fulfilling their duties to one party
could impair their ability to perform their duties forthe other party.

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Discrimination
Discrimination refers to unfair or unequal treatment of
individuals or groups based on certain characteristics
such as age, disability, race, national origin, gender,
religion or sexual orientation.
EntityCommercial entity means any corporation, partnership,
limited partnership, proprietorship, sole proprietorship,
firm, enterprise, franchise or association that performs
a commercial activity in a particular jurisdiction. It
has a legal existence separately identifiable from theindividual owner of the business.
Ethics Everywhere Helpline
Our secure online reporting tool which is managed onbehalf of JLL by an independent third party. The
Everywhere Helpline and online service are available
24/7 in more than 160+ languages, and in mostcountries you can choose whether you want toremain anonymous.
Facilitation payments
Small payments (also called ‘speed’ or ‘grease’
payments) made to secure or expedite the performanceof a routine or necessary action, such as to obtain apermit or license.
Gifts and entertainment
Business courtesies such as offering or providing itemsof any value, experiences, travel expenses, charitable
contributions, hospitality.

JLL Vendor Code of Conduct

Government official
A government official is defined broadly and includes
government employees, anyone acting on behalf ofa government, employees of a state-owned business,
employees of public international organizations, elected
officials and political candidates, customs or tax
officials, military personnel, and family members of aperson mentioned above.
Harassment and bullying
Harassment is unwanted conduct that violates aperson’s dignity or creates an intimidating, hostile,
degrading, humiliating or offensive environment.
Bullying is a type of harassment that most often relieson psychological tactics to control or dominate thetarget, using power or position to coerce others by fearor to oppress them by force or threat.
Human rights
Human rights are the basic freedoms that belong
to everyone in the world, regardless of race, sex,
nationality, ethnicity, language, religion or any otherstatus. Human rights include the right to freedom fromslavery and torture, freedom of opinion and expression,
the right to work and education, and many more. JLL
promotes human rights as defined by the International
Bill of Human Rights, the International Labor
Organization’s Declaration on Fundamental Principles
and Rights at Work, the United Nations Global Compact
and the United Nations Guiding Principles on Businessand Human Rights. Everyone is entitled to these rights
without discrimination.

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Integrity
Behaving in a fair, ethical and honorable way. Being
honest and embracing ethical principles consistently
and without compromise to build trust. Integrity means
doing the right thing, even when no one is watching.
Intellectual property
Intellectual property refers to ownership of an idea
or design by the person who developed it. Copyright,
patents, designs and trademarks are legal ways toprotect intellectual property. Examples include:• Acquisition and divestiture plans• Internal financial information• Proprietary technology and software• Proprietary research and data
• JLL or our client information, including pricing
information, profit and loss models, prospects,
requests for proposals and legal documentation• Client lists and portfolio and property information of
JLL or our client• Information and databases owned by JLL or our client• Business strategies and models• New product and marketing concepts• Litigation strategies and information• Processes, trade secrets, business know-how
and best practices that are intended to provide
competitive advantages• Risk management and insurance information

JLL Vendor Code of Conduct

Modern slavery
Modern slavery involves exploiting vulnerable
individuals for profit. It is a crime and a violation of
fundamental human rights. It takes various forms, suchas servitude, forced and compulsory labor, child labor,
debt bondage and human trafficking.
Money laundering
Money laundering is an illegal process which involves
converting money or assets obtained through criminal
activity, such as drug trafficking or terrorist financing,
into assets that appear legitimate.
Retaliation
Retaliation occurs when adverse action is taken
against a person and can take many forms, including
deliberate exclusion from opportunities or promotion,harassment, intimidation, microaggressions, unjustified
negative performance reviews or termination of
employment. Regardless of tenure or job position,
retaliatory behaviors are never acceptable and anyone
who engages in any of these behaviors will be subject
to disciplinary action up to and including terminationof employment.
Social media
Social media is computer-based technology thatfacilitates sharing ideas and information through virtual
networks such as blogs, chat rooms and online forums.
Social media channels include, for example, Facebook,Weibo, LinkedIn, Instagram, TikTok and Pinterest.

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Supply partners
Vendors, suppliers, or other providers ofgoods and services.
Terrorist financing
Terrorist financing is connected to money launderingand involves using money or assets, whether legitimate
or obtained through criminal activity, to fund terrorist
activities or groups.
Trade and economic sanctions or restrictions
Trade and economic sanctions are political restrictions
targeting countries, entities and individuals deemed
to be threats to national or international peace andsecurity. The goals of sanctions are to force designatedcountries, entities and individuals to alter behavior by
cutting off access to economic activity.

JLL Vendor Code of Conduct

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 $20.9 billion and operations in over
80 countries around the world, our more than 103,000 employees
bring the power of a global platform combined with local expertise.
Driven by our purpose to shape the future of real estate for abetter world, we help our clients, people and communities
SEE A BRIGHTER WAYSM. JLL is the brand name, and a registeredtrademark, of Jones Lang LaSalle Incorporated. For further
information, visit jll.com.

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