avatar Jones Lang Lasalle Incorporated Finance, Insurance, And Real Estate
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    Ethics Everywhere Annual Report Calendar Year 2017


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    Table of Contents Introduction 03 Why we report on our Ethics program 05 2017 Report 07 Benchmarking 10 Ethics recognition 11 Ethics Everywhere program components 12 Helpline 12 Ethics Liaison Program 13 Training Efforts 13 Our Priorities 14 Conclusion 15 Appendices 16 2018 Jones Lang LaSalle, Inc. All rights reserved. 2


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    Introduction JLL is committed to a corporate culture that Click to edit Master text styles embraces and promotes strong principles of business and professional ethics. Ethical practices are inherent in our values, mission and strategy, and must guide all of our interactions with clients, customers, vendors, and employees. The JLL Ethics Everywhere program establishes the Ethics Everywhere at JLL was launched in 2003. framework for the various The backbone of our program is JLL’s global activities JLL undertakes in network of Ethics Officers. They are responsible order to: 1) maintain for maintaining and continually enhancing the Ethics Everywhere program and performing compliance with the firm’s periodic reviews of our business practices, Code of Business Ethics procedures, policies and internal controls for and 2) to detect, compliance with the Code. investigate, and resolve any violations of its provisions. JLL’s Ethics Officers believe it is a best practice to transparently disclose the data we collect during the year. The information in this Report reflects all of the companies globally in the Jones Lang LaSalle Incorporated group (including LaSalle Investment Management). 2018 Jones Lang LaSalle, Inc. All rights reserved. 3


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    Introduction One of the most significant elements of a company’s Click to edit Master text styles sustainability program is the quality of its culture and the integrity of its people. Ethics Everywhere is therefore a foundational pillar of our overall corporate sustainability program, Building a Better Tomorrow. Accordingly, as we strive to be an increasingly transparent member of the global community, it is important to evaluate the ethical culture of our organization and establish a public framework for measuring our continuing efforts. We seek to We include information from this Ethics make every year better than the previous one. Annual Report in our public Sustainability Report, and we post this full Annual Report We believe that transparency enhances the quality on our website as part of our core corporate of our program, and everyone’s compliance with it. information. By disclosing the ethics matters we investigated during 2017 and the actions we took in response, we hope to demonstrate that we take every integrity allegation seriously and that there will be significant consequences for those who breach the trust we place in each of our colleagues. Building a 2018 Jones Lang LaSalle, Inc. All rights reserved. 4


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    Why we report on our Ethics program At the end of 2017, we had more than 82,000 employees world-wide, a significant increase from the 22,000 staff we had in 2005, and there are many thousands of additional contractors and suppliers with whom we work. Given this large and growing number of people, as well as the complexity and vast geographical dispersion of our business, we expect to be conducting a number of ethics investigations at any one time. Indeed, our employees’ use of the Ethics Everywhere reporting process to raise compliance questions and concerns is actually the sign of a healthy culture, since it indicates that we have created an environment that employees encourages everyone to come forward with ethics issues because they understand and trust our strong world-wide corporate policy of not retaliating against anyone who raises a concern in good faith. 2018 Jones Lang LaSalle, Inc. All rights reserved. 5


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    Why we report on our Ethics program Click toour We also want our people, on whom we rely to promote editethical Master text styles culture, to understand why working for an ethical company benefits them personally. This is because a highly ethical company: • Attracts top clients and superior talent • Makes it easier to win and keep business, and expand existing relationships • Strengthens personal brand and reputation • Creates a solid platform for pursuing career goals in a work environment based on mutual respect • Avoids distractions caused by ethical lapses • Saves money, which can be reinvested in the workforce • Creates a sense of pride that comes from working for a trustworthy company 2018 Jones Lang LaSalle, Inc. All rights reserved. 6


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    2017 Report No company of our size can expect to be Click addressed to themtext edit Master through stylesactions such as entirely free of ethics investigations or additional training on our ethics policies where violations. However, we believe that our we determined there was inadequate organization as a whole continues to awareness of the rules or where there had demonstrate a high level of ethics awareness been misunderstandings. and communication. In the best global employee engagement survey, which was We would not expect to ever substantiate completed by over 31,000 employees, 97% 100% of all allegations, since there are typically agreed that they understood their obligations some situations where we determine that either under the Code of Business Ethics, which was (1) false allegations were made in bad faith, (2) the highest scoring of all of the questions. allegations were made in good faith but were proven untrue due to misunderstandings, or (3) The number of ethics concerns raised in 2017 anonymous allegations were made which rose 39% from the prior year, and the number limited our ability to conduct a full investigation. of investigations per 100 employees rose from 0.83 to 1.02. We have become more sophisticated in our ability to get to the truth of the matter in these In 75% of the investigations we conducted in situations, including, for example, our use of 2017, we determined that something had in fact cloud technology to search emails. taken place (even if we could not fully substantiate the claim) and deserved follow-up During 2017 we also significantly improved our action of some kind. This is greater than the use of data forensic techniques, which allow us 59% in the prior year. better access to expense reports. This in turn allows us to look for potentially abusive In certain cases, these actions were serious, situations ourselves before they are reported such as terminations of employment (including from outside parties such as other employees, reporting criminal acts to the police). In other clients or vendors. cases, they were less serious, and we 2018 Jones Lang LaSalle, Inc. All rights reserved. 7


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    2017 Report Our complete ethics statistics are presented at Click terminations to edit Masterin text the prior year but still only styles the end of this report, including comparisons 0.2% of our population, illustrating JLL's to prior years and benchmarking against data commitment to take action in order to protect on other companies that was published by and promote an ethical workplace. Navex Global*, the provider of our helpline services. It should also remain a sobering indication of the very real financial and personal risks taken Ethics statistics are inherently difficult to when one engages in unethical behavior, as interpret accurately. An increase in the number the firm is able to successfully investigate of allegations could mean that the ethical many complaints and is also willing to take environment of an organization has appropriate actions in response. deteriorated. But it could also reflect a positive development in terms of our efforts to Almost all of these situations could have been communicate our ethics policies, or that avoided with some common sense or employees have become more comfortable personal self-policing, and it is almost always bringing their concerns to the firm and using the case that the personal financial loss from the systems we have in place to identify, termination far exceeded the benefit gained prevent, or manage potential unethical from the unethical behavior. behavior. Today, an increased use of technology and And as noted above, the increase can also be forensics, together with better reporting of attributed to our enhanced ability to mine the concerns by colleagues, makes it increasingly data in our systems in order to detect potential unlikely that misconduct will go undetected. expense abuse and other types of fraud and We hope that knowledge of this will itself help conflicts of interest. deter bad conduct that can lead to serious personal consequences. In 2017, there were 167 cases where serious ethical lapses resulted in termination of *Navex Global 2018 Ethics & Compliance Hotline & Incident Management employment. This is up 25% from the 134 Benchmark Report 2018 Jones Lang LaSalle, Inc. All rights reserved. 8


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    2017 Report Some reported ethics concerns resulted from unintended Click to edit Master text styles mistakes or misunderstandings, and we conducted individual or group training to address those situations. Some allegations were determined to be unfounded or not supported by sufficient evidence. In a few cases, we determined that allegations were falsely made in order to get one of our employees in trouble due to personal conflicts or to try to hide or establish an excuse for poor performance. Additionally, some of the allegations involved employees of clients or vendors. In all cases where we were able to determine intentional non-compliance, we took disciplinary action including employment termination. Where there was possible criminal conduct, we also contacted local law enforcement authorities. The investigations we conducted in 2017 resulted in 560 disciplinary or other actions such as changing reporting relationships. 2018 Jones Lang LaSalle, Inc. All rights reserved. 9


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    Benchmarking We show below how our global Helpline statistics compared to the benchmarks we received from our helpline provider, Navex Global. Navex publishes an annual benchmarking report* with data gathered from the many companies for which it provides helpline services. Detail Navex Global Survey JLL Cases per 100 Employees Median 1.4 1.02 Anonymous Reports 56% 19% % of calls that are inquiries only 20% 3.4% Civility and other HR matters as a % 72% 58% of all reports Open door (in-person) v. hotline 39% of cases are open door 74% of cases are open door reporting Substantiation Rate 44% 58% Americas 86.2% Americas 42% Geographic Reporting APAC 9.3% APAC 49% EMEA 4..5% EMEA 9% JLL’s results were slightly lower than Navex's average in terms of cases per hundred employees (1.02 versus 1.4), and our substantiation rate was higher (58% versus 44%). Our geographic reporting percentage was more evenly distributed across our regions. In both JLL’s experience and in the benchmarking, the highest number of overall cases were related to employment and civility matters, although JLL’s number was lower than Navex's average (58% versus 72%). *Navex Global 2018 Ethics & Compliance Hotline & Incident Management Benchmark Report 2018 Jones Lang LaSalle, Inc. All rights reserved. 10


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    Ethics recognition In 2017, we were honored to receive the following awards: • We were named by the Ethisphere® Institute as one of the “World’s Most Ethical Companies” for the 10th year in a row. The list recognizes over 130 companies from around the world for their commitment to ethical business practices. The list reflects companies in 41 industries and 21 countries. No other real estate services company has been on the list for as long as JLL, and very few other companies have been on the list for as long. • For the second year in a row, JLL was also named to Corporate Responsibility (CR) Magazine's list of the 100 Best Corporate Citizens in the United States, and JLL was again first in the Financial Services / Insurance / Real Estate sector. • JLL was named to the Dow Jones Sustainability Index (North America) for the second time. • JLL was again named one of FORTUNE Magazine’s “World’s Most Admired Companies.” 2018 Jones Lang LaSalle, Inc. All rights reserved. 11


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    Ethics Everywhere program components Helpline Of the total number of concerns raised in 2017, 233 (or 26% of the total number of investigations) were made through our global helpline telephone number or our reporting website. Most of the calls we receive through the helpline are from within the United States, but the calls we receive from other countries are fairly dispersed, indicating that there is general awareness among our colleagues worldwide that the helpline is available to them. We continue to communicate internally about our helpline and our non-retaliation policy to make sure employees know how to report concerns without fear of being treated unfairly as a result. The helpline is, of course, only one method of communicating concerns. We encourage colleagues to be comfortable communicating directly with their managers, one of the Ethics Officers, or their Human Resources representative. We feel it positively reflects on our program that the great majority of the concerns were made directly to one of our people internally, indicating a justified confidence that claims will be handled appropriately through means that are not necessarily anonymous. 2017 2016 2015 2014 2013 2012 2011 2010 Total number of concerns raised via calls to 233 179 104 56 65 52 49 30 global helpline or emails to website 2018 Jones Lang LaSalle, Inc. All rights reserved. 12


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    Ethics Everywhere program components Ethics Liaison program Click to edit Master text styles In 2011, we established our Ethics Liaison program. This program seeks to appoint an employee within adopting business units and client accounts to be the liaison between their co- workers and JLL’s Ethics Officers. Ethics Officers hold quarterly calls with Ethics Liaisons, share relevant media and thought leadership content, and advise on engagement strategies for employees who spend most of their time at a client location. We now have more than 160 ethics liaisons globally. We have made significant progress in continuing to establish our Ethics Liaison program within many of our largest client accounts and within a number of our countries. Through this mutual partnership, we believe we can make the principles of our Code of Business Ethics more accessible to all of our colleagues. We also believe that having a “point person” available on a local level will help identify and mitigate any ethical issues or dilemmas that may arise, which will in turn help maintain our global reputation as an ethical organization. Training Efforts Our Ethics Officers engage in significant training and communication efforts. These include: in-person training during business meetings, providing content and input to new hire orientation, and periodic messaging through the Company’s newsletters. We also provide articles, videos and presentations on the Company’s intranet, which receives thousands of hits each year. During 2017, we reached over 9,000 staff during more than 200 in-person training sessions. In addition, over 13,000 employees completed ethics related training in our online training tool, MyDevelopment. 2018 Jones Lang LaSalle, Inc. All rights reserved. 13


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    Our Priorities Looking forward, we are implementing additional initiatives Click to edit Master text styles to ensure that all our staff have the knowledge, tools and resources to respond to challenging situations, including better use of MyDevelopment, the Company’s global Learning Management System (LMS), and translation of materials into our global employees' native languages. Centralizing our training within the LMS will allow for better tracking and metrics so that we can tailor targeted training to certain businesses and groups, for example, fraud training targeted to our global Finance professionals. Our LMS also allows us to create a more efficient process for obtaining annual certifications of compliance with our Code of Ethics, which we have begun in 2018. We are also further developing our forensic capabilities internally in order to mine the data in our system for the purposes of increasing our investigative capabilities and alerting us to potential ethics concerns. Additionally, we have expanded our Professional Standards and Communications functions within our Legal Services group, which are focused on improving internal awareness and controls. Finally, we have launched BizHack, which helps our people apply scientific principles to enhance many aspects of their daily activities such as interviewing, making presentations and negotiating. BizHack also has modules on improving the ethical environment and generally being more careful with personal behaviors. 2018 Jones Lang LaSalle, Inc. All rights reserved. 14


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    Conclusion The continued success and excellent reputation of JLL Click to and edit LaSalle Master Investment text styles Management depend on the manner in which our employees conduct themselves. Acting with integrity and the highest ethical standards is not only good policy, it's good business. 2018 Jones Lang LaSalle, Inc. All rights reserved. 15


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    ()JLL


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    Global Insights Of 884 total cases: • 366 cases occurred in India (41%) • 333 cases occurred in the U.S. (38%) • Together, these two countries make up 79% of all of our ethics investigations in 2017. 366 333 Cases Cases occurred in India 41% occurred in the U.S. 38% Top Investigations / Claims: 2018 Jones Lang LaSalle, Inc. All rights reserved. 17


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    Global Investigation Data Charts The overall increase in the number Ethics Investigative Data – 2017 of investigations is in line with an increase in employee population. Total # of investigations 884 Total # of substantiated and/or partially 435 substantiated claims There was an increase in cases Total # of investigations where we took some kind of action 560 where claims were not necessarily substantiated, but taking action was Total # of unsubstantiated cases 222 still deemed prudent (such as more Total # of open and/or pending 135 training or changes to processes). Total # of inquiries (not reporting an incident) 31 Total # of employees 82,000 Note on Data Charts: Data reflects cases opened between 1/1/17 and 12/31/17. Case status data is current as of 2/14/18. 2018 Jones Lang LaSalle, Inc. All rights reserved. 18


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    Global Investigation Data Charts Number of Investigations per 100 Employees 1.02 0.82 0.83 0.57 0.53 0.47 0.27 0.29 0.19 2009 2010 2011 2012 2013 2014 2015 2016 2017 Number of Employees vs. Number of Investigations 1000 90,000 900 80,000 800 70,000 700 60,000 600 50,000 500 40,000 400 30,000 300 20,000 200 100 10,000 0 0 2009 2010 2011 2012 2013 2014 2015 2016 2017 Total Number of Employees Total Investigations 2018 Jones Lang LaSalle, Inc. All rights reserved. 19


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    Global Investigation Data Charts Global - Total Investigations vs. Substantiated and/or Partially Substantiated Claims 2017 0 20 40 60 80 100 120 Abandonment 45 Antitrust 0 4 Compensation, Wages, or Improper Pay 12 42 Conflict of Interest 31 59 Data Privacy 12 10 Disclosure of Confidential Information 9 15 Discrimination - Age 1 15 Discrimination - Disability 1 11 Discrimination - Gender 4 11 Discrimination - National Origin 12 Discrimination - Other 2 7 Discrimination - Race/Ethnicity 10 32 Discrimination - Religion 24 Environmental Protection, Health or Safety Violations of Law… 4 10 Fraud - Bribery & Kickbacks 27 55 Fraud - Improper Accounting Practices 16 25 Fraud - Money Laundering 12 Fraud - Theft & Embezzlement 41 51 Fraud - Timekeeping Falsification 14 12 Fraud - Travel and Expense Account Misuse 68 Fraud - Work Order Falsification 89 Fraudulent Background Check 20 30 Gifts 58 Harassment - Hostile Work Environment & Bullying 58 114 Harassment - Sexual 54 84 Insider Trading 13 Leave of Absence, Return to Work & Acommodations 2 7 Misuse of IT Systems or Property 12 18 Other 37 91 Performance Management 5 29 Regulatory Compliance 2 5 Retaliation 3 17 Scope of Work 01 Substance Abuse 9 17 Unfair Treatment & Favoritism 8 39 Workplace Violence 17 26 Unknown 2 Total Investigations Substantiated and/or Partially Substantiated Claims 2018 Jones Lang LaSalle, Inc. All rights reserved. 20


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    Global Investigation Data Charts 2017 Total Investigation Results Partially Substantiated 17% Unsubstantiated 30% Insufficient Information 5% Other 7% Substantiated 41% 2018 Jones Lang LaSalle, Inc. All rights reserved. 21


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    Global Investigation Data Charts Year Over Year Investigation Data 2017 2016 2015 2014 2013 2012 2011 2010 2009 Total Number of 884 638 503 333 250 253 133 77 100 Investigations Total Number of 82,000 77,000 61,500 58,100 52,700 48,000 45,000 40,000 37,000 Employees Number of 1.02 0.83 0.82 0.57 0.47 0.53 0.29 0.19 0.27 Investigations per 100 Employees Total Number of 435 328 346 277 183 194 52 52 65 cases where we determined there was an ethics violation Percentage of 58% 51% 69% 83% 73% 77% 77% 68% 65% investigations Substantiated Substantiated where we and/or partially substantiated the substantiated claim and/or took some kind of 75% action 59% action action taken taken Number of 560 375 346 277 183 194 113 52 65 Actions Taken 2018 Jones Lang LaSalle, Inc. All rights reserved. 22


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    For any questions, please contact our Ethics Officers listed on our website at: http://www.jll.com/about/ethics-everywhere 2018 Jones Lang LaSalle, Inc. All rights reserved. 23


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    © 2018 Jones Lang LaSalle IP, Inc. All rights reserved. All information contained herein is from sources deemed reliable; however, no representation or warranty is made to the accuracy thereof. It is the intellectual property of Jones Lang LaSalle IP, Inc. and should not be replicated.


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