jll.com

Whistleblower and
Non-Retaliation Policy

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Global Whstleblower & Non- retaliation Policy

Our commitment
JLL is committed to maintaining the highest ethical standards and to engaging in practices
that enhance the welfare, safety, and well-being of our employees, business partners, andwider communities. We encourage reporting of any action that appears to be in violation of
our Code of Ethics (the “Code”) or an internal policy.

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Global Whstleblower & Non- retaliation Policy

PurposeThe purpose of this policy is to reaffirm JLL’s commitment to comply withwhistleblowing laws:
To encourage a “speak up” culture within JLL by setting out reasonable standards tomanage our mechanisms for reporting and investigating reports and;To ensure effective protection from possible negative consequences, such as acts ofretaliation towards any person who has reported an activity that has occurred in awork-related context and that they honestly believe is wrongful or unlawful.

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Global Whstleblower & Non- retaliation Policy

Scope
Who can report under this policy?
Any person who honestly believes an activity or conduct is wrongful or unlawful including
any of the following:• Employees, volunteers, trainees, interns, (managing) directors, officers, non-executive
members and shareholders;• Third parties (e.g., clients, the self- employed, contractors, suppliers or consultants,
including their employees), visitors, or facilitators who assist those who speak up(e.g., colleagues or relatives who could be impacted by a report of any wrongful or
unlawful activity) and legal entities the Reporter owns, works for or is in some way
connected within a work-related context• Including those whose work-based relationship has yet to begin (e.g., pre-contractual
negotiations) or has ended (in the case of former employees) or4

Global Whstleblower & Non- retaliation Policy

What kind of conduct or activity can be reportable under this policy?
• JLL encourages you to report any conduct or activity that has occurred in JLL’s
work-related context that you honestly believe is wrongful or unlawful, including:• Illegal activity including the violation of law, regulations or industry norms related to ouroperations and activities• Improper or misleading accounting or financial reporting practices• Fraud, theft or financial abuse including bribery and corruption practices• Activity breaching money laundering and terrorist financing laws

• Behavior that poses a serious risk to human rights, the health and safety of any personat the workplace or to public health, public safety or the environment in connection withour business operations within JLL and its direct suppliers• Violating data protection and IT security laws
• Unethical behavior including violence, discrimination or sexual or other formsof harassment or• Any other kind of misconduct or violation of our Code, internal policies, laws
and regulations• Unfair competition and insider trading practices

Personal work- related conflicts
These conflicts normally refer to concerns or disputes raised in our personal relationsin the workplace with other colleagues, who are also JLL employees, after experiencing
a perceived injustice or a disagreement. These conflicts may be about a variety ofissues, for example:• Concerns or disputes relating to payment or benefits(not connected to an act of retaliation)• Complaints about unsatisfactory working conditions or changes such as a transfer,promotion, or disciplinary action which are not connected to an act of retaliation• These are not whistleblowing disclosures, and you should raise them directly raised
Human Resources team or via HR DIRECT following JLL’s applicable Human Resources
policies and procedures• Frustration with too much work.

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When can I make areport under this policy?
If you have a concern, witness or suspect actions that areinconsistent with our Code, internal policies or the law, you
should speak up so that we can take appropriate action.
You can raise a concern without being certain somethingis wrong; you will still be protected under this Policy. If
you honestly believe something is not right, you should
speak up. We treat all reported concerns seriously andfairly and, if needed, we will take action based on what wehave learned. However, before making a report, you should
satisfy yourself that you reasonably and honestly believethat the conduct reported is not right.
You must not make a report that you know is not trueor is misleading. We consider this a serious matter that
may result in disciplinary action. There also may be legal
consequences if you knowingly make a false report.

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Global Whstleblower & Non- retaliation Policy

Reporting channels
How can I make a whistleblowing report?
You can contact JLL’s independent, anonymous and secure Whistleblower service available in multiple languages, 24 hours a day, 365 days a year, through these channels:

Ethics Everywhere Helpline

Report Online

Contact our Ethics Everywhere Helpline

Access via https://jll.ethicspoint.com

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Global Whstleblower & Non- retaliation Policy

You can also make a report directly to:
Human ResourcesYour manager or
any Senior Leader

An Ethics Officer

Legal, Ethics& Compliance

We encourage you to consider the use of any of the channels mentioned offered by JLL
to report. We want to hear your concerns directly so that we can address them promptly.
There are a lot of advantages if you use JLL’s internal reporting channels:• You are contributing to a proactive and effective response to the issue• You can remain anonymous if you use our Helpline or Online channels• You are assured that confidentiality will be maintained to the extent possible inaccordance with applicable laws

Global Chief Legal Officer

Chief Ethics &Compliance Officer

Chair of the Board

Chief
Audit Officer• Reporting ethical issues helps JLL make things right, strengthen our ethical culture andprotect our employees from harm
Note: Local laws in some countries require us to provide local reporting channels
where you can elect for your report to be managed locally. For specific information andrequirements around local reporting channels in the EU countries please refer toAppendix D at the bottom of this Policy.
Also, refer to Appendix C to see what specifics apply in this section for Australia.

• You are assured that all reported matters will be reviewed professionally andtreated consistently

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Global Whstleblower & Non- retaliation Policy

Can I report externally?
Yes. Although JLL prefers that you raise concerns directlywith us through any of the mentioned JLL internal
channels, you may choose not to use any of them andto report the wrongful or unlawful activity directly to arelevant authority without involving JLL in the process.
Provided that any criteria established in applicable laws
are met, including situations that may involve an imminent
danger to the public interest, a risk of retaliation, or a
failure to deal with concerns internally, you also may makea public disclosure. However, before making any suchdisclosure, you may want to seek external advice tounderstand the criteria and be able to choose the way you
want to report.
For specific information and requirements around externalreporting in Australia and the EU Countries please refer toAppendix C & D respectively at the bottom of this Policy.

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Global Whstleblower & Non- retaliation Policy

Treatment of internal reportingand investigation process
How can I make a whistleblowing report?
If you made a report by contacting a person such as your manager, it will be escalated tothe appropriate team within Legal or Human Resources. If you report a concern through our

Ethics Everywhere Helpline or online, you will receive a report key (a unique number) andpassword to use to follow up on your report.

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We will thoroughly assess the report to determine if an investigation is necessary. If it isnot, we will take appropriate actions to address the concern. We review all reports and takethem seriously.
Anonymous reporters do not receive notification when the case manager posts a commentor question within our case management platform. Therefore, we encourage anonymous

reporters to log into the platform on a daily basis for updates and to respond to anyquestions or comments from the case manager.
Please go to “Can I remain anonymous when using JLL reporting channels?” section under
this Policy for more detail on anonymous reporting at JLL.

Who will be conducting
the investigation?
Helpline and online reports go directly to a global team of dedicated, professional
investigators who review the report based on the geographic location and type of concern
before assigning it to a case manager who will contact you.
The case manager may rely upon local Legal & Compliance teams and other subject-matter
experts (such as IT or Human Resources) to provide support where necessary. Under certain
circumstances, JLL may engage outside counsel or an external investigation firm.
In any case, we will process relevant personal information securely, responsibly and in aconfidential manner in accordance with applicable privacy laws as well as JLL’s Global
Privacy and Data Protection Policy and JLL Privacy statement.
This process may differ slightly in some countries where local laws impose specificrequirements for reporting. Please check Appendix D for the EU countries’ specifics
regarding local reporting.
Visit the “Confidentiality when using JLL reporting channels” section under this Policy forfurther details.
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What does an investigation look like?
The case manager will conduct an impartial investigation and treat you fairly and withrespect. They will review evidence and interview people involved. Although we will try tokeep your identity confidential, this may not always be possible in order for us to conduct a
proper investigation and / or to comply with any duty to report misconduct externally.

If you report anonymously and have not provided your email address, use your report key
to check for status updates and respond to additional questions to assist the investigation.
You will find in Appendix A an Ethics Reports Workflow with detailed steps typically taken in
the investigations process for whistleblowing cases from receipt of a report to case closure.

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How do we update reporters on developments and closure?
We communicate follow-up information and feedback as soon as practicable within areasonable timeframe, always in compliance with applicable laws. Response time depends
on the nature and seriousness of the allegations. In any case, for Helpline or online
reports, you will receive an acknowledgement receipt within 48 hours from the date thecase is reported.
Based upon the evidence, the case manager will make a determination and, whereappropriate, issue their recommendations. If a concern is substantiated, we will takeappropriate action. We will notify you when we resolve the matter, and the case manager
will update the case record before closing the case.
To protect the confidentiality of the investigation and the parties to it, we might be able toshare only limited information and updates and may not be able to share outcome details
with you. However, we will provide with as much information as we can in compliance withapplicable laws.

What might happen to an individual found to have engaged in wrongdoing?
If the investigation reveals any subject wrongdoing or unlawful activity, a critical next step is
to take adequate action, based on objective criteria and proportionate to the wrongdoing.
This could include a verbal or written reminder of JLL policy, mandatory training, a formal
verbal or written warning regarding behavior, termination of employment, or referral to law
enforcement in accordance with local laws, which may trigger JLL’s obligation to report thewrongdoing or unlawful activity to the relevant authority.
Consequences for the wrongdoing could extend beyond the actual wrongdoer to include
those who knew or should have known of some aspect of wrongdoing or unlawful activity.

In any case, the decision to take appropriate action will involve different stakeholders within
Legal & Compliance, HR, other support Leads or even an external law firm or consultant.
and it will be based on objective criteria in order to make the action taken proportionate to
the wrongdoing.
For further information about local requirements regarding local reporting channels andinvestigations resources in the EU countries, please refer to Appendix D at the bottomof this policy.

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Global Whstleblower & Non- retaliation Policy

Can I remain anonymous when using JLL reporting channels?
Yes. If you are uncomfortable speaking directly with someone in JLL, in most countries you
can choose to remain anonymous by calling our Ethics Everywhere Helpline or using ouronline reporting tool. However, anonymous reports may make it more difficult for us tothoroughly investigate the issue. Therefore, providing as much information as possible will
help us understand, investigate and successfully resolve your issue.
The case manager relies on the Reporter to respond to questions and provide additional
information to thoroughly investigate your concern. If you wish to remain anonymous whencalling our Helpline or for online reports, you will be able to follow up on any updates toyour report, provide additional information or documentation and/or respond to questions
from the case manager in two ways:• By using the report key assigned to you to login and providing any additional
information requested• By providing an email address when logging a report. Anonymous reporters who
provide an email address when logging a report can protect their anonymity and havethe case manager send communications automatically through a portal to their email
address. Because JLL cannot see email addresses provided to the independent service
provider that manages our Ethics Everywhere Helpline, we ensure anonymity for all
anonymous reporters
A small number of countries restrict anonymous reporting, and if applicable to yourlocation, you will learn this when you call the Ethics Everywhere Helpline or begin
your online report.
In all events, JLL treats all reported concerns seriously and fairly and, if needed and to theextent legally possible, we will take action based on what we have learned

Confidentiality when using JLL reporting channels
JLL will keep the matter and the Reporter’s identity as confidential as possible. That means
we will disclose information in the report and the Reporter’s or cooperating witnesses’
identities only on a need-to-know basis or when applicable laws require disclosure.

For more details on how confidentiality applies in particular in Australia and the EU
countries please go to Appendix C & D respectively.

Please refer to Appendix B - Protection of Personal Data for further detailregarding Disclosures.

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Global Whstleblower & Non- retaliation Policy

JLL’s Non-Retaliation Policy
We do not tolerate any form of retaliation against anyone who:
• Reports a concern or complaint of misconduct and who honestly believes thatsomething is not right• Cooperates with an investigation or• Refuses to do something that violates our Code, internal policies or the law

Individuals who engage in retaliation will be subject to disciplinary action by JLL, up to andincluding termination of employment. Retaliatory actions that violate the law could also
subject the individual to legal liability.
Note that this Policy will not protect you from potential disciplinary action if you, as aReporter, are also involved in or connected to improper conduct or illegal activities that are
the subject of a report.

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We are committed to fighting all forms of retaliation. However, retaliation can take many
forms and sometimes it may be difficult to identify that this is happening. The following
scenarios are some examples of potential signs of retaliation:• Suspension, lay-off, dismissal; failure to renew, or early termination of a temporary
employment contract

As a reinforcing measure to prevent retaliation in our company, we have put in placea “retaliation monitoring.process” in order to be able to detect any form of retaliation
resulting from speaking up
Please refer to Appendix C & E for more information on Retaliation specifics that apply forAustralia and the US• Demotion or withholding of promotion or of training• Transfer of duties, change of location of place of work, reduction in wages, change
in working hours• A negative performance assessment or employment reference• Disciplinary measures, reprimands or other penalties, including a financial penalty• Intimidation, harassment, discrimination• Failure to make a temporary employment contract into a permanent one
where the worker had legitimate expectations that he or she would be offeredpermanent employment• Harm, including to the person’s reputation, particularly in social media, or financial loss,
including loss of business and loss of income• Limiting an individual from finding another job within such as by blacklisting on thebasis of a sector or industry-wide informal or formal agreement, which may indicate theindividual will not be employed in the industry in the future
If you believe that you are experiencing retaliation after speaking-up or because you
intended to speak-up, you should report it to us, and we will take appropriate steps inaccordance with this and JLL’s other policies

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Key terms
For the purposes of this Policy, the following definitions apply:“Local requirements” appendixes C, D & E to this Policy contain local specificrequirements to comply with applicable laws and regulations in Australia, the EU Countries
and the U.S. respectively“JLL” Jones Lang LaSalle Incorporated (including its majority-owned subsidiaries and
LaSalle Investment Management)“JLL Confidential Information” means highly sensitive information proprietary to JLL or
JLL’s clients that could seriously damage JLL if such information was lost or made public2“Independent company” is a service provider that delivers anonymous and secure
Whistleblower reporting services to JLL“JLL Restricted Information” means information that, if disclosed by JLL to unauthorizedparties (outside of or within JLL), could notably disrupt JLL’s operations, significantly impact
our competitive advantage, damage our reputation or result in financial loss1
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Global Whstleblower & Non- retaliation Policy“Personal work-related conflicts” refers to behavior that affects the Reporter personally,
namely concerns about interpersonal conflicts between the Reporter and another
employee that are not a consequence of retaliation, and do not implicate JLL or its
business operations“Public disclosure” information on wrongful or unlawful activity made available publicly.
Public disclosures can only be made under limited circumstances determined by applicablelaws and following specific criteria“Relevant authority” means any local authority or government agency, including its
officials, charged with the enforcement of any laws and/or designated to receive reports inaccordance with local whistleblowing laws
“Retaliation” occurs when adverse action is taken against a person as a result of making
a report, being part of an investigation (as a witness or a contributor) or asking a question.
Visit “JLL’s Non Retaliation Policy “section in this document for further details“Whistleblower”, “reporter” is any person listed under “Who can report under thispolicy” section below, who reports any wrongful or unlawful activity and is qualified forprotection under this policy“Work-related context” means current or past work activities developed either from a JLL
office location, at a client site, home office or any other remote working location, throughwhich potential Reporters acquire information on wrongful or unlawful activities taking
place in connection to JLL and within which those persons could suffer retaliation if theyreported such information“Wrongful or unlawful activity” means any activity within JLL’s work-related context that
violates applicable law, the Code or an internal policy.

This term shall have the same meaning given by Corporate Governance Policy Information Classification.
This term shall have the same meaning given by Corporate Governance Policy Information Classification.

1
2

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Administrationof policy
The Global Chief Legal Officer is the issuer and owner of this Policy, in consultation with theChief Executive Officer. The Policy shall be subject to periodic review and revision by the
Global Chief Legal Officer as necessary or appropriate and in periodic consultation with theChief Executive Officer.
Please refer to Appendix C as to how this Policy will be distributed to officers andemployees in Australia.

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Legal restrictions
on the applicationof this policy inparticular countries
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We intend this Policy to apply to JLL globally. However, if a provision of this Policy would
violate an applicable local law or regulation, then that provision will not apply to ouremployees or operations within that country or location.
We will incorporate any additions or changes to this Policy as necessary, in order to meetcountry-specific obligations. In any case, where local applicable laws expand Reporters’rights not gathered in this Policy, they will still apply.
This Policy shall not affect either the application of local law relating to any of the following:

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The protection of classified information

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The protection of legal and medical professional privilege

3

The secrecy of judicial deliberations

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Rules on criminal procedure21

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Issuance and revision history
Date: April 2021
Review Date: September 2023

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Appendix A:
Ethics Reports
Workflow23

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Case closed
Case assigned

Case assignment
The case manager is provided
with case details for review todetermine whether to open an
investigation where appropriate.

Updates to reporter
Reporter notification
The case manager will contact
the reporter to confirm that an
investigation has been opened
and request additional
information if necessary.

Acknowledgment of receipt

Report logged

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Investigation opened

Case triage
Notifications of helpline or online reports arereceived by the global triage team (or to the
local triage team for reports1 submitted locally)
for review and assignment (based on
the location and type of concern raised) to acase manager. For reports addressed throughother means, assignment is completed by legal,
ethics & compliance or HR teams.

refer to appendix D for more information on local reporting channels’ process

The case manager will
monitor any potential
signs of retaliation
towards the reporterand key witnesses.

Follow-up actions
When applicable, the casemanager will ensure thatthe appropriate actions
have been implemented.

The case manager updates the caserecords and closes the investigation in thecase management platform.

The case manager begins collecting
evidence (i.E. Paper documents,
emails, electronically stored
data,etc.), Interviewing witnesses
and subject matter experts.
Ethics everywhere helpline and online
reports go directly into JLL casemanagement platform for assignment.
Reports made to individuals such as amanager or ethics officer are escalated tothe appropriate case manager within
legal, employee relations or HR whomanually enters details into the platform.

Monitoring
retaliation

Investigation closed

An acknowledgement of receipt is sent
to the reporter within 48 hours.

Case opened

The reporter will be
informed about thecompletion of theinvestigation and whereappropriate, of any
actions taken.

Case outcome
If the facts are verified, the case manager
will share any recommendations with the
management and HR concerning theappropriate action to be taken.

Case investigatedUpdates to reporter
The reporter will be updated on
the progress of the investigation
as appropriate and whenever
the duration exceeds 90 days.

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Appendix B: Protection of
Personal Data
This appendix explains how JLL collects, uses and shares personal data for Speak Up
purposes. This includes any personal data relating to the Reporter, as well as personal data
about those individuals against whom a report has been made or those who have been
identified as having information about the report.

For more general guidance on how JLL handles your personal data please see JLL’s Global
Privacy and Data Protection Policy and JLL Privacy Statement on our external website.

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Personal data
The sort of personal data JLL holds as part of the reporting process may include:Your name and contact
details (if you decide not toreport anonymously).

The name and title of theindividual(s) you may
be reporting.

A description of
any questionableconduct, including all
elevant details; andAny question you may
have that relates to you
or any other individual.

Sensitive personal data, as defined by JLL’s Global Information Classification Policy and by
applicable privacy laws and regulations, could be also included in the report.

Purpose of data processing
JLL may process your personal data.
• To administer the speak up service and assess and follow-up on submissions to the
speak up service• To investigate alleged violations• To take any necessary follow-up action upon the completion of an investigation• To create anonymous reports for our company’s management
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Legal basis
We rely on legitimate interests as the lawful basis for the collection and use of your personal
data. Where sensitive personal data is collected, we will rely on an appropriate legal basis
to process such data. We will only process your personal data in ways compatible withthe purpose for which it was collected. To the extent necessary for such purposes, we willtake reasonable steps to make sure that personal information is accurate, complete andotherwise reliable with regard to its intended use. With regard to a Speak Up process, JLL
shall use your personal data in line with JLL’s Global Privacy and Data Protection Policy.

Disclosures
Personal data collected for the purposes referred to above will be shared with our
independent service provider who administers the Speak Up Service on behalf of andunder the direction and control of JLL. In some cases, we may also rely on an external law
firm or consultant to access your personal information for the purpose of assisting with theinvestigations in relation to (suspected) violation(s) of our Code of Ethics and/or policies.
When we share personal information with these third parties JLL requires that they only

use such personal information as necessary to provide investigatory services to us and in amanner consistent with JLL’s Global Privacy and Data Protection Policy and applicable law.
The processing of relevant personal information is carried out securely and responsibly.
Furthermore, personal data collected for Speak Up purposes will only be disclosed to any
other party if our Company is under a duty to disclose or share your personal data in order
to comply with any legal obligation or when necessary to report criminal offenses.

Cross Border Transfers
Calls and on-line reports to the Speak Up Service are received on behalf of JLL by anindependent service provider based in the United States with servers located within various
EU member states. We have taken the necessary measures to ensure that any personal
data gathered by our independent service provider is adequately secured and processed forauthorized Speak Up Service purposes only.

We have in place a framework agreement which incorporates standard contractual clauses
to enable JLL entities to transfer and process personal data within the JLL group (IntraGroup Data Transfer Agreement or “IGDTA”). Its purpose is to help JLL group companies
demonstrate compliance with both the EU General Data Protection Regulation (GDPR), andany other applicable Data Protection Legislation.

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Retention of reports and investigations records
Copies of all reports, investigations information and resolution will be maintained in accordance with JLL’s Global Document and Records Management and Retention Schedule Policy.

Personal information rights
You may at any time want to exercise your privacy rights of access, objection, rectification, restriction or erasure. To exercise any of these rights or if you have a complaint about our handlingof your Personal Data with regard to the Speak Up procedure, use our online form for personal information rights requests.

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Appendix C:
Australia’s Specifics
This appendix applies (in addition to the Global Whistleblower & Non-Retaliation Policy) toanyone who discloses conduct warranting protection under Australia’s whistleblower laws.
The following text is added under the global policy headings as indicated or, in the case of“Confidentiality when using JLL reporting channels”, certain text is replaced.
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This appendix applies (in addition to the Global Whistleblower & Non-Retaliation Policy) toanyone who discloses conduct warranting protection under Australia’s whistleblower laws.
The following text is added under the global policy headings as indicated or, in the case of“Confidentiality when using JLL reporting channels”, certain text is replaced.

Personal work-related conflicts• Add: “In Australia a personal work-related conflict may still be protected if• it includes information about misconduct• we have breached certain employment or other laws, engaged in conduct that represents
a danger to the public, or the Reportable Conduct relates to information that suggests
misconduct beyond your personal circumstances• you suffer from or are threatened with detriment for making a disclosure; or• you seek legal advice or legal representation about the operation of Australia’s
whistleblower laws.”

How can I make a whistleblowing report?
Add: “In Australia, reports can also be made to our external auditor”.
Can I report externally?
Add: “A “relevant authority” in Australia includes the Australian Securities & Investments
Commission (“ASIC”), Australian Prudential Regulation Authority (“APRA”), the Australian
Taxation Commissioner (“ATO”) and any other prescribed body”• at least 90 days have passed since you made the disclosure to ASIC, APRA or anotherprescribed body• you do not have reasonable grounds to believe that action is being, or has been taken, in
relation to your disclosure• you have reasonable grounds to believe that making a further disclosure of theinformation is in the public interest and• before making the public interest disclosure, you have given written notice to the relevant
authority (to which the previous disclosure was made) that• includes sufficient information to identify the previous disclosure; and• states that you intend to make a public interest disclosure
An “emergency disclosure” is the disclosure of information to a journalist or aparliamentarian, where:• you have previously made a disclosure of the information to ASIC, APRA or anotherprescribed body;• you have reasonable grounds to believe that the information concerns a substantial
and imminent danger to the health and safety of one or more persons or to thenatural environment;• before making the emergency disclosure, you have given written notice to the relevant
authority (to which the previous disclosure was made) that:

A “public disclosure” includes a “public interest disclosure” and an “emergency disclosure”.

• includes sufficient information to identify the previous disclosure; andA “public interest disclosure” is the disclosure of information to a journalist or aparliamentarian, where:• states that you intend to make an emergency disclosure; and30

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the extent of the information disclosed in the emergency disclosure is no greaterthan is necessary to inform the journalist or parliamentarian of the substantial or
imminent danger.”“Disclosures to a legal practitioner for the purpose of obtaining legal advice or legal
representation in relation to the operation of Australia’s whistleblower laws are protecteddisclosures under this Policy.”

Administration of Policy
Add: “Information about this policy will be provided to all Australian officers and employees:• with their contracts of employment; and• at least annually via email.”

Confidentiality when using JLL reporting channels
Replace: “That means that the issue and the identity of the Reporter, as well as cooperating
witnesses, will be disclosed only on a need- to- know basis or when otherwise required tobe disclosed by applicable laws”
With: “Subject to compliance with legal requirements, we will only share your identity as aReporter, or information likely to reveal your identity, if:• you consent;• the concern is reported to a relevant authority (such as ASIC, APRA or a member of theAustralian Federal Police); or• the concern is raised with a lawyer for the purpose of obtaining legal advice
or representation.
If you wish to lodge a complaint with us about a breach of confidentiality, you
should contact Legal, Ethics & Compliance. You may also lodge a complaint with arelevant authority”

Non-Retaliation
Add: “All employees in Australia (and their eligible immediate family members) have accessto our Employee Assistance Program, available through HR Direct.”31Global Whstleblower & Non- retaliation Policy

Appendix D: EU
Countries’ Specifics
This Appendix applies to all JLL companies located within a EU Member State1 in order
to comply with requirements in the DIRECTIVE (EU) 2019/1937 OF THE EUROPEANPARLIAMENT AND OF THE COUNCIL of 23 October 2019 on the protection of persons whoreport breaches of Union law.
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Confidentiality
All reporting is done confidentially. This means that your identity and information about your report will be confidential and only shared with a limited number of people on a strict needto-know basis for the purpose of handling your report. This information will not be disclosed outside this small group (typically local Legal & Compliance teams and other subject- matter
experts such as IT, Human Resources or under certain limited circumstances, an outside counsel or an external investigation firm) without your explicit consent unless we are required to do
so by law or to protect or defend our rights or those of our employees, clients, suppliers or business partners, or where we have determined that the allegations were malicious.
Please note that in some cases we may also rely on an external law firm or consultant to assist with the investigation. For further details, please refer to Appendix B – Protection of
Personal Data.

Local reporting channels & investigations resources
JLL has a global team of dedicated, professional investigators who will manage your reported concern in coordination with local case managers following a professional, fair and globallyconsistent process.
This team reports directly to Global & Regional senior Management, not to local Management, thus guaranteeing full independence and impartiality in the handling of reports.
Your reported concern will be handled by the global professional investigations team as mentioned above. You can also elect for your report to be handled locally if you prefer so. In any case,be assured that the same fair and globally consistent standards apply whether your case is investigated by our team of professional investigators or our local team.
If applicable to your location, this option will be made available when you call the Ethics Everywhere Helpline or begin your online report.

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List of external reporting authorities you can report toSome Member States have designated local competent authority/ies to receive and investigate whistleblower disclosures and retaliation complaints. In the table below you will find the list
and relevant links in case you want to visit.

Country

Authority

Link

Austria

Austrian Federal Competition Authority

https://report.whistleb.com/en/bwb

Belgium

The Federal Ombudsman  FSMA to receive and investigate whistleblower reports regarding violations of the law on
financial instruments supervised by the FSMA  
CTIF-CFI to receive and investigate whistleblower reports

https://www.fsma.be/en/faq/whistleblowers-point-contact

Bulgaria

Bulgarian Commission for Combating Corruption and Confiscation of Illegally Acquired
Property

https://www.minfin.bg/

Croatia

Ombudsman  * Based on previous regulation. Keep an eye on any updates

https://www.ombudsman.hr/en/

Czech Republic

Ministry of Justice is the designated governmental body to receive and supervise externalreports*There is still no local law in place implementing EU directive*Keep an eye on any updates

https://www.mvcr.cz/mvcren/article/ministries-and-governmental-offices-ministriesand-governmental-offices.aspx

Denmark

Danish Data Protection Agency (Datatilsynet)

https://whistleblower.dk/english

FinlandChancellor of Justice’s OfficeFinnish Financial Supervisory Authority (FIN-FSA) maintains a system for receiving reportsof suspected infringements of financial market provisions (whistleblowing system)

https://oikeuskansleri.fi/en/whistleblower-protection
https://www.finanssivalvonta.fi/en/about-the-fin-fsa/report-suspected-infringement/

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FranceJudicial authorities, administrative authorities or professional bodies  
In any case, any person may address their alert to the French Defender of Rights (Défenseur
des Droits) to be directed to the appropriate body competent for receiving the alert.
However, the Defender of Rights is not competent to process and investigate reports except
when an alert falls within the four areas of his competence, of which discrimination is one

The list of competent authorities according to the subject of the alert is annexed to
the Decree published in the Official Journal  
https://www.defenseurdesdroits.fr/fr/saisir

Germany

A central external reporting office is to be established at the Federal Office of Justice (BfJ).
In addition, the existing reporting systems at the Federal Financial Supervisory Authority(BaFin) and the Federal Cartel Office (Bundeskartellamt) are to be continued as further
external reporting offices with special responsibilities

https://www.bafin.de/DE/DieBaFin/Hinweisgeberstelle/hinweisgeberstelle_node.
html
https://www.bundeskartellamt.de/DE/Kartellverbot/Anonyme_Hinweise/anonymehinweise_node.html

GreeceNational Transparency Authority (N.T.A.)

https://aead.gr/en/

Hungary

Ombudsman’s Office*Based on previous regulation. Keep an eye on any updates

https://www.ajbh.hu/web/ajbh-en

IrelandCentral Bank of Ireland where the information relates to a firm regulated by the Central
Bank or to an individual within such a firm that is involved in wrongdoing
Irish Auditing and Accounting Supervisory Authority
Several other bodies are designated as prescribed persons for reporting wrongdoings too.
These are set out in detail in S.I. No. 339/2014

https://www.centralbank.ie/regulation/protected-disclosures-whistleblowing
https://www.gov.ie/en/collection/41798-protected-disclosures-whistleblowing-list-ofprescribed-persons/#
https://www.irishstatutebook.ie/eli/2014/si/339/made/en/print

Italy

ANAC or to judicial or accounting authorities only with regards to the public sector (public
employees)

http://www.anticorruzione.it/portal/public/classic/
Email to: protocollo@pec.anticorruzione.it

Luxembourg

CAA and CSSF are competent authorities regarding the companies they supervise

https://www.caa.lu/fr/whistleblowing
https://whistleblowing.apps.cssf.lu/index.html?language=en

Malta

Commissioner of Revenue (CfR)  
Financial Intelligence Analysis Unit (FIAU)
Malta Financial Services Authority (MFSA)  
Commissioner for Voluntary Organisation (CVO)
Permanent Commission Against Corruption  
Ombudsmanhttps://justice.gov.mt/en/justice/whistleblower/Pages/Whistleblower%27s-Act.aspx
Email to: whistleblower.helpmail@gov.mt

Netherlands

Dutch Whistleblowers Authority

https://www.huisvoorklokkenluiders.nl/english

PolandNo such external authority has been established yet*Keep an eye on any updates

N/A

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Portugal

National Anti-Corruption Mechanism  https://dre.pt/dre/detalhe/lei/93-2021-176147929

Romania

No such external authority has been established yet*Keep an eye on any updates

N/A

Slovakia

No such external authority has been established yet.
*Keep an eye on any updates

N/A

Spain

Autoridad Independiente de Protección del Informante*Keep an eye on any updates

N/A

SwedenSwedish Financial Supervisory Authority (Finansinspektionen) is responsible for receiving
reports on regulatory violations  
Swedish Work Environment Authority is responsible for the areas where no other authority
is competent to receive and investigate whistleblower complaints and has also the
responsibility to exercise supervision that employers have established internal reporting
channels

https://www.fi.se/en/about-fi/contact-us/whistleblowers/
https://www.av.se/en/about-us/contact-us/?hl=Whistleblowing

Local, regional and/or national authorities should be contacted in the first instance, however, the whistleblower may also turn to the competent EU institutions, bodies or organizations forreceiving reports on breaches of EU law when conditions are met. For further details please click here.

EU Member States for the purposes of this Policy are intended to be: Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania,36
Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain and Sweden.
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Global Whstleblower & Non- retaliation Policy

Appendix E:
U.S. Specifics
This appendix applies (in addition to the Global Whistleblower & Non-Retaliation Policy) toanyone who discloses conduct warranting protection under US laws.

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Global Whstleblower & Non- retaliation Policy

Non- Retaliation
Following the U.S. Defend Trades Secret Act, any person whether or not a JLL employee, isallowed to disclose information (including JLL restricted and/or confidential information)
directly or indirectly to a relevant authority or to a lawyer if the disclosure is for the purposeof reporting or investigating a suspected law breach., The information disclosed must benecessary to reveal the violation.

Further, we will not prevent Reporters from disclosing JLL restricted and /or confidential
information in a complaint (filed using confidential measures) where the disclosure isnecessary to reveal the violation subject of the whistleblowing report. JLL will not require
any reporting person to sign a confidentiality agreement regarding the alleged wrongdoingor unlawful activity, or any agreement that would prohibit reporting an alleged wrongdoingor unlawful activity.

38About JLL
For over 200 years, JLL (NYSE: JLL), a leading global commercial real estateand investment management company, has helped clients buy, 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 theworld, 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 a better world, we help our clients, people
and communities SEE A BRIGHTER WAY. JLL is the brand name, and aregistered trademark, of Jones Lang LaSalle Incorporated. For further
information, visit jll.com.

jll.com