Legal

Executive Summary Tishman Speyer is firmly committed to preventing bribery, both in the United States and abroad. Tishman Speyer has in place a Global Anti-Corruption Policy (“Anti-Corruption Policy”) that requires Tishman Speyer employees to act in compliance with the U.S. Foreign Corrupt Practices Act, the UK Bribery Act, and all other applicable anti-corruption laws. Tishman Speyer’s Anti-Corruption Policy:

• Confirms that Tishman Speyer is deeply committed to preventing bribery — whether direct or indirect and in the private or public sectors;
• Mandates anti-corruption training for all Tishman Speyer employees, including more extensive, targeted training to employees whose responsibilities carry inherent corruption risk;
• Explains how Tishman Speyer employees may report corruption-related issues;
• Requires the accurate maintenance of books and records;
• Prohibits employees from giving or receiving cash or cash equivalents;
• Establishes a set of procedures so that when anything of value is given to a party outside Tishman Speyer the giving is documented to show that the benefit is reasonable, customary, and proportionate to the underlying business purposes related to it;
• Sets forth pre-clearance thresholds for giving certain business hospitality, gifts, charitable contributions, sponsorships, political contributions, and referred candidates;
• Requires employees to report certain business hospitality and gifts received from parties outside Tishman Speyer;
• Prohibits facilitation payments; and
• Establishes a system of compliance controls used when hiring third parties that pose corruption risks to the firm.

Compliance with anti-corruption laws is critical for Tishman Speyer as it protects not only Tishman Speyer, but also its investors from the abuses associated with corruption.