The case for CSR/ Sustainability Reporting Done Responsibly


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Case study: How CBRE promotes compliance and business integrity

CBRE is the world’s largest commercial real estate services and investment firm, operating in over 480 offices with more 90,000 employees, and serving clients in more than 100 countries worldwide. CBRE is firmly committed to conducting its business with the highest integrity  Tweet This!, and in compliance with the letter and spirit of the law.

This case study is based on the 2018 Corporate Responsibility Report by CBRE published on the Global Reporting Initiative Sustainability Disclosure Database that can be found at this link. Through all case studies we aim to demonstrate what CSR/ ESG/ sustainability reporting done responsibly means. Essentially, it means: a) identifying a company’s most important impacts on the environment, economy and society, and b) measuring, managing and changing.

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CBRE’s Ethics and Compliance programme maintains and supports a consistent culture of values that acts as the cornerstone of CBRE’s global business philosophy, so that its success is achieved in the right way. In order to promote compliance and business integrity CBRE took action to:

  • implement a Standards of Business Conduct (SOBC) policy
  • provide an Ethics Helpline

What are the material issues the company has identified?

In its 2018 Corporate Responsibility Report CBRE identified a range of material issues, such as employee attraction & retention, greenhouse gas emissions, human rights, diversity & inclusion, climate change resilience. Among these, promoting compliance and business integrity stands out as a key material issue for CBRE.

Stakeholder engagement in accordance with the GRI Standards

The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:

“The organization should identify its stakeholders, and explain how it has responded to their reasonable expectations.”

Stakeholders must be consulted in the process of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.

Key stakeholder groups CBRE engages with:   

Stakeholder Group                Method of engagement


·       Quarterly earnings calls

·       Investor presentations, events & one-on-one meetings



·       Client Care programme

·       Localised research resources and insights

·       Response to information requests

Employees ·       Global employee intranet and email communications

·       Employee engagement survey

·       Employee network groups

Suppliers ·       Supplier Code of Conduct

·       Supplier Diversity Programme

Industry associations and sustainability organisations ·       Participation on boards and committees

·       Presentations and attendance at conferences and events


How stakeholder engagement was made to identify material issues

To identify and prioritise material topics CBRE engaged with both internal and external stakeholders through calls, where stakeholders were asked to rate topics according to importance.

What actions were taken by CBRE to promote compliance and business integrity?

In its 2018 Corporate Responsibility Report CBRE reports that it took the following actions for promoting compliance and business integrity:

  • Implementing a Standards of Business Conduct (SOBC) policy
  • CBRE’s Standards of Business Conduct (SOBC) is the senior-most policy in the company, guiding CBRE’s everyday operations and bringing its RISE (Respect, Integrity, Service and Excellence) values to life. The SOBC outlines expectations of employee conduct relating to each other, CBRE’s business partners, clients and competitors, CBRE’s corporate resources and CBRE’s communities. It is the focal point of CBRE’s culture of ethics and compliance and essential to preserving the trust placed upon CBRE by its clients. Available in 30 languages and approved by the Board of Directors, all employees are required to read, understand, certify annually and adhere to the SOBC. Through the certification process, every employee reaffirms his or her commitment to the RISE values and CBRE’s standards, as well as adherence to several specific policies (for example, harassment prevention, anti-bribery, anti-corruption, confidentiality, data privacy). Employees are also encouraged to report any suspected material wrongdoing of which they might be aware. In 2018, 94% of employees completed the SOBC certification, an increase of 2% over 2017.
  • Providing an Ethics Helpline
  • CBRE focuses significant energy and resources on sustaining its internal avenues for inquiries, bringing forth concerns and investigating suspected unethical or illegal activities. Led by the Chief Ethics & Compliance Officer, this infrastructure includes a worldwide anonymous reporting (as permitted by local laws) and inquiry system, the Ethics HelpLine, available 24 hours a day and accessible in all languages, used by CBRE employees. These third-party independent systems are promoted through CBRE’s corporate communications, office posters and internal training, and are easily accessible through the Internet and country-specific toll-free phone numbers. The Ethics & Compliance department is independent from business operations, so questions can be posed and advice given in a non-attributable, confidential and comfortable manner. In addition, if an allegation of serious misconduct is logged into the system by an employee or third party, internal investigators are required to conduct a prompt, thorough and unbiased investigation consistent with internal policies. Uniformity of process and outcomes in an investigation is achieved by requiring investigators to attend annual training and regular case peer review meetings. In 2018, CBRE received 1,135 reports through the Ethics HelpLine, online systems, and by speaking with members of the Human Resources, Compliance and Legal Departments. The categories of concerns spanned all aspects of workplace misconduct, from fraud and conflicts of interest to harassment and discrimination. Of the reports that led to an investigation into violations of CBRE’s policy or the law, approximately half resulted in some kind of remedial measure, including employee discipline.

Which GRI Standards and corresponding Sustainable Development Goals (SDGs) have been addressed?

The GRI Standard addressed in this case is: Disclosure 419-1 Non-compliance with laws and regulations in the social and economic area


Disclosure 419-1 Non-compliance with laws and regulations in the social and economic area corresponds to:

  • Sustainable Development Goal (SDG) 16: Promote peaceful and inclusive societies for sustainable development, provide access to justice for all and build effective, accountable and inclusive institutions at all levels
  • Business theme: Compliance with laws and regulations


80% of the world’s 250 largest companies report in accordance with the GRI Standards

SustainCase was primarily created to demonstrate, through case studies, the importance of dealing with a company’s most important impacts in a structured way, with use of the GRI Standards. To show how today’s best-run companies are achieving economic, social and environmental success – and how you can too.

Research by well-recognised institutions is clearly proving that responsible companies can look to the future with optimism.

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1) This case study is based on published information by CBRE, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:


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