Anti-Corruption Policy

Jones Lang LaSalle Incorporated

Anti-Corruption Compliance Program

COPYRIGHT © JONES LANG LASALLE IP, INC. 2020. All Rights Reserved

Global | May 2020

Anti-Corruption Policy

JLL’s Anti-Corruption Compliance Program
JLL aims to prevent bribery and corruption in all of our businesses, wherever we do business. The framework forour anti-corruption program incorporates guidance from the U.S. Department of Justice and other international
standards to effect compliance with anti-bribery laws and to detect potential violations. This framework issupported by business processes and procedures designed to minimize the risk of bribery and corruption.
Features of JLL’s Anti-Corruption Program
1. A Code of Business Ethics including a clear policy
against making and taking bribes, as well as prohibiting
facilitation payments of any kind. Our Vendor Code ofConduct similarly prohibits bribery of any kind. JLL
is firmly committed to ethical behavior in all of its
business practices.
2. A Global Corporate Governance Anti-Bribery Policy
addressing JLL’s commitment to integrity andtransparency through a robust anti-bribery andcorruption program, and Risk Management Guidelines
on detecting potential bribery situations, performing
due diligence for third-party intermediaries, uncoveringrisks in mergers and acquisitions, and implementing
controls for gifts and entertainment, charitable giving
and finance-related roles.
3. Intranet sites containing business-oriented tools
designed to help our employees prevent bribery or
spot and report potential bribery situations. These
tools include an Anti-Bribery Manual covering potential
bribery risks, how to spot them, and actions to preventor report potential violations; and a Manager’s toolkit tofacilitate training on bribery and conflicts of interest.
4. Contract clauses for vendors and suppliers to warrant
that they have a policy to comply with anti-bribery /corruption laws and have had no significant violationsof such laws.
5. JLL’s Ethics Everywhere Global Curriculum, available

to all employees through JLL’s learning management
system, which includes training modules on antibribery / corruption, conflicts of interest, fraud and gifts.
6. A Global Internal Audit team that operates a riskbased anti-bribery work program incorporating
questionnaires, interviews and testing protocols as
part of its regular audit procedures for JLL businesslines and country operations.
7. Focus on improper risk associated with mergers
and acquisitions.
8. Training for new employees, including employees
joining JLL after an acquisition, concerning what itmeans to work at a publicly traded company, which
includes the importance of complying with anti-bribery
laws. New joiners also have access to training modules
on bribery risk in JLL’s learning management system.
9. Multiple options for JLL employees and others to report
actual or potential violations of our Code of Business
Ethics or any anti-corruption laws. These options
include reporting to managers, the Chief Ethics andCompliance Officer or a regional Ethics Officer; making
an anonymous report by calling our 24-hour Ethics
Worldwide Helpline; or submitting an anonymous
written report online to our third-party ethics vendor.
JLL prohibits retaliation, retribution or harassment
against any employee who in good faith asks questions
or raises concerns.

JLL periodically reviews its Anti-Corruption Compliance Program to evaluate its effectiveness and to implement
necessary changes.

COPYRIGHT © JONES LANG LASALLE IP, INC. 2020. All Rights Reserved