Legal & Important Disclosures

INTRODUCTION

Tishman Speyer does not and will not tolerate modern slavery or human trafficking. This statement is made under Section 54 of the UK Modern Slavery Act 2015 and outlines the steps Tishman Speyer has taken during the financial year 2025 to assess, prevent and eliminate, as far as possible, the risk of modern slavery and human trafficking taking place within its UK bases and as part of its supply chains.
The term "modern slavery" is used in this statement to describe a variety of situations and behaviours such as slavery, servitude, forced marriage, forced labour, debt bondage, deceptive recruitment practices, child labour and human trafficking, amongst others.

OUR BUSINESS

Tishman Speyer offers an integrated platform for global real estate expertise that serves the needs of prestigious organisations across the world. It is a world-leading real estate developer and owner and prides itself on creating exceptional, award-winning spaces. Each project is managed as a stand-alone business with our development, construction, investment and property management teams working cohesively to ensure that we create enduring value around the world. Tishman Speyer’s long-standing and reputable presence in key markets across the world is underpinned by highly experienced teams, who are not only experts in their fields, but experts within their respective markets. Tishman Speyer’s global footprint extends across Europe, Brazil, North and South America, India and China. Tishman Speyer UK works with property management, corporate and design and construction suppliers based in and outside the UK. Materials associated with design and construction were procured by Tishman Speyer UK via its subcontractors that came from various parts of the world.

OUR UK SUPPLIERS

Suppliers

In 2025 Tishman Speyer’s UK business worked with eighty-nine (“89”) construction, technical, engineering and building contractors (the “Construction & Property Suppliers”). Tishman Speyer internal functions such as property management, design and construction, manage day-to-day relationships with its Construction & Property Suppliers.

Under Tishman Speyer’s standard UK operating procurement processes, Construction & Property Suppliers are subject to pre-onboarding risk-based due diligence and name screening, on matters including but not limited to financial-crime, sanctions, adverse media and reputational (the “Background Screening”). In performing the Background Screening, Tishman Speyer utilises sophisticated software tools to perform risk-based screening of its UK Suppliers, that may alert it to potential risks of modern slavery and human trafficking in its Construction & Property Supplier’s supply chains, prior to their engagement. As part of this pre-onboarding process, Construction & Property Supplier are also required to acknowledge and sign agreements to comply with Tishman Speyer’s ‘Responsible Contractor Requirements’, committing to paying workers fair wages and benefits, utilise fair employment practices, and to providing safe workplaces that are supportive of compliance with the MSA 2015. Tishman Speyer monitors on an ongoing risk-basis, its Construction & Property Suppliers’ potential exposure to modern slavery and human trafficking risks.

Where screening or other due diligence identifies information potentially relevant to modern slavery, human trafficking or associated misconduct, the matter is escalated for further review. Depending on the nature and severity of the issue, additional information or enhanced due diligence may be required and Tishman Speyer may require remediation, impose additional contractual controls or determine not to establish or continue the supplier relationship.

In the financial year ending 31 December 2025, c. ninety-two per cent (“92%”) of Tishman Speyer’s UK businesses total spend was with Construction & Property Suppliers who were able to evidence published statements on their commitment towards combatting risks as evidenced by modern slavery statements. In addition, c. ninety-five per cent (“95%”) per cent of Tishman Speyer’s UK business’s total spend was with Construction & Property Suppliers approved through Background Screening.

Tishman Speyer recognises that certain activities within the real estate and construction sectors may present an inherently greater exposure to modern slavery and human trafficking risks, particularly where labour-intensive services, migrant workers, subcontracting arrangements or extended supply chains are involved.

Taking into account the nature of its UK operations, the supplier risk assessment undertaken during 2025 and the due diligence, screening, contractual and monitoring controls applied by Tishman Speyer, no matters were identified through this review that caused Tishman Speyer to assess its residual exposure to modern slavery and human trafficking as high. Tishman Speyer will continue to monitor these risks and enhance its controls where appropriate.

OUR COMMITMENT TO TACKLING MODERN SLAVERY

Tishman Speyer’s guiding principles are underpinned by the need to treat everyone with respect and civility. By this very standard and, as a responsible business which sets itself to the highest standards, Tishman Speyer does not, and will not, tolerate modern slavery or human trafficking within its UK bases or as part of its supply chains.

WITHIN OUR ORGANISATION

Tishman Speyer has a comprehensive compliance manual which is overseen by its Compliance Officer. The Compliance Officer is responsible for ensuring that this manual is kept up-to-date and reflects any new or amended regulatory requirements. The compliance manual sets out various regulations and regulatory regimes that apply to employees of Tishman Speyer and contains its whistleblowing policy. Through the compliance manual and whistleblowing policy, Tishman Speyer maintains its commitment to honesty, openness and accountability. It encourages staff members to voice concerns, raise issues and challenge poor practice and behaviour. Tishman Speyer takes all allegations of misconduct, both internally and amongst our suppliers, very seriously and where evidence of misconduct is found this may result in disciplinary action or discontinuation of business relationships, as appropriate. The whistleblowing policy also contains our commitment to a policy of non-retaliation against individuals who raise complaints or concerns. All Tishman Speyer staff can report inappropriate or suspicious behaviour via our anonymous EthicsPoint hotline.

Tishman Speyer has committed to hold itself to the highest standards by conducting business professionally and with integrity. We take concerns regarding alleged breaches of our codes of conduct very seriously. Tishman Speyer also maintains Responsible Contractor Requirements that requires our contractors to satisfy our standards with respect to conducting their business in an honest and ethical manner. Through this, contractors are required to ensure that workers are paid properly and fairly and that they utilise fair employment practices. Failure to comply may result in the discontinuation of business relationships.

Tishman Speyer also maintains a disciplinary and grievance policy which clearly sets out the ways in which any member of staff can raise concerns. We are committed to handling grievances and disclosures in a proper and prompt manner.

DUE DILIGENCE, RISK MANAGEMENT AND KEY PERFORMANCE INDICATORS

During 2025, Tishman Speyer considered and assessed the extent to which the organisation is exposed to modern slavery and human trafficking within its workplace. We assessed the risk of human trafficking and modern slavery by considering Construction & Property Suppliers against the following factors:

• Country risks – consideration is given to the jurisdictions from which labour, goods and materials may ultimately be sourced, including whether those jurisdictions present heightened risks relating to forced labour, human trafficking or inadequate worker protections.
  
• Sector risks – we recognise that construction, property management and certain labour-intensive services may present heightened modern slavery risks. Relevant factors may include the use of subcontracted or agency labour, migrant and temporary workers, recruitment practices, low-paid or vulnerable workers and complex supply chains through which Tishman Speyer may have limited direct visibility beyond its first-tier suppliers.
  
• Transaction risks – consideration is given to unusual payment arrangements, the nature and value of the services being provided, use of intermediaries or labour providers, subcontracting arrangements and other circumstances that may indicate an increased risk of exploitation or a lack of transparency within the supply chain.
  
• Business partnership risks – consideration is given to the nature of the supplier, its workforce and subcontracting model, the services provided, relevant adverse information, the existence of appropriate modern slavery controls and, where applicable, the supplier's own Modern Slavery Act statement.

A risk rating is then applied to each vendor internally. This process is conducted on a consultative basis involving inputs from various teams within the business (design & construction, human capital management, property management, compliance, procurement and corporate). These risk ratings are then reviewed annually.

Due to these internal controls, no matters were identified that caused Tishman Speyer to assess its residual exposure to modern slavery and human trafficking within the workplace as high. However, Tishman Speyer shall continue to monitor the organisation’s processes on a regular basis and where necessary, will take action to reduce a potential increase in risk.

During 2025, Tishman Speyer also undertook an extensive review of Tishman Speyer’s UK Corporate & Property Suppliers. An exhaustive list of these suppliers was compiled and reviewed as part of an in-depth supply chain and vendor risk assessment. Tishman Speyer assessed and ranked each supplier’s potential exposure to modern slavery and human trafficking.

Taking account of the findings from the risk assessment and the controls described above, Tishman Speyer did not identify matters requiring its residual modern slavery risk assessment to be increased to high. Tishman Speyer shall continue to monitor and assess risks from its UK supplier-base.

TRAINING

Tishman Speyer staff are made aware of the company's zero tolerance approach and policies to modern slavery and human trafficking.

CONCLUSION

Tishman Speyer will continue to monitor its exposure to modern slavery and human trafficking within the UK, both within the workplace and as part of its supply chains. In instances where increased exposure is identified, Tishman Speyer will seek to implement measures to ensure that any such risks are reduced, if not, eradicated.

This statement constitutes Tishman Speyer’s modern slavery and human trafficking statement for the financial year ending 31 December 2025.