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"JLL’s Ethics Everywhere program embodies our commitment to a corporate culture that embraces and promotes strong principles of business and professional ethics at every level. In general, JLL’s policies and procedures are designed to identify unethical business partners before we engage them and to monitor our suppliers to make surethey maintain ethical standards that match JLL’s.

The principal document articulating JLL’s core values of Teamwork, Ethics and Excellence is our Code of Business Ethics, published in multiple languages on our website. In addition, our Codes provide options for reporting violations or potential violations that are available to employees and to our suppliers, such as calling JLL’s Global Ethics Helpline or using JLL’s ethics reports website, contacting one of JLL’s Ethics Officers, or sending a letter to JLL’s Global General Counsel and Chief Ethics Officer.

JLL’s Corporate Governance Policies include a separate policy addressing Anti-Slavery and Human Trafficking, which applies to all JLL employees and, through our Codes and contractual provisions, to suppliers and other third-party business associates worldwide. The policy identifies specific prohibited activities, and includes mechanisms for employees to report violations or potential violations of the policy. We also have a Corporate

Governance Policy devoted to Vendor Due-diligence that prohibits doing business with suppliers engaging in illegal practices or any questionable practices that may result in credit, reputation, or litigation issues for JLL.

Recently updated to align with our procurement due-diligence process, the Vendor Due-diligence Policy includes consideration of modern slavery activities in determining risk of retaining particular suppliers. JLL’s Supply Chain Management and Procurement’s (SCMP’s) Global Procurement Policy echoes our corporate zero-tolerance approach to modern slavery, and reiterates employees’ obligation to ensure that suppliers do not engage in or participate in modern slavery in any form."

"Throughout all of our global operations, these suppliers must attest in a pre-engagement questionnaire and in their ontract with JLL that they do not engage in any of the activities comprising modern slavery, and must renew that attestation annually."