1. Vendor/Client/Tenant/Landlord Jones Lang LaSalle Due Diligence
July 2012

2. Vendor/Client/Tenant/Landlord Due Diligence
Introduction
Legislation
US FCPA
UK Anti-Bribery Act
OFAC and Other Non-US Government Prohibited Persons Lists
What this means for Jones Lang LaSalle
Measures We Have in Place to Comply
Focus on Accelus – a Due Diligence Tool
Appendix

3. Introduction
Jones Lang LaSalle is committed to a corporate culture that embraces and promotes strong principles of business and professional ethics at every level. Ethical practices are inherent in our values, mission and strategy, and must guide all of our interactions with clients, customers, vendors and employees. Our Board of Directors and senior management take these responsibilities seriously, both for themselves and the rest of the organization. We conduct due diligence on the 3rd parties we do business with. Our procedures are appropriate to the situations and are designed to reflect the following due diligence practices we have in place to comply with global legislation in support of our vendor / client / tenant / landlord due diligence commitment.

4. US Foreign Corrupt Practices Act (FCPA)
Prohibits the bribery of foreign officials in an attempt to reduce corruption and money laundering through the global financial system. Corrupt political officials are targeted with a view to preventing government officials from exploiting their positions to gain unfair commercial advantage.
Applies to US and foreign firms and persons who cause, directly or through agents, an act in furtherance of such a corrupt payment to take place within the territory of the US, this can include bank transfers through US banks or USD accounts
Prohibits corrupt payments through intermediaries. It is unlawful to make a payment to a third party, while knowing that all or a portion of the payment will go directly or indirectly to a foreign official. The term "knowing" includes conscious disregard and deliberate ignorance.

5. UK Anti-Bribery Act
Covers business that takes place in the UK and with UK companies globally and UK citizens. This Act replaces the common law offence of bribery, with two general offences:
Offering, promising or giving an improper advantage (broadly, bribing another person)
Requesting, agreeing to receive or accepting an improper advantage (broadly, seeking or receiving a bribe)
The Act also creates two further specific offences:
An offence of bribery of a foreign public official in order to obtain or retain business
A new offence applicable to a commercial organisation that fails to prevent a bribe being paid by a person associated with it with the intention of obtaining or retaining business or an advantage in the conduct of business

6. US Office of Foreign Assets Control (OFAC) and Other Non-US Government Prohibited Persons Lists
The Office of Foreign Assets Control (OFAC) of the US Department of the Treasury administers and enforces economic and trade sanctions based on US foreign policy and national security goals against targeted foreign countries and regimes, terrorists, international narcotics traffickers, those engaged in activities related to the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the United States.
OFAC acts under Presidential national emergency powers, as well as authority granted by specific legislation, to impose controls on transactions and freeze assets under US jurisdiction. Many of the sanctions are based on United Nations and other international mandates, are multilateral in scope, and involve close cooperation with allied governments.
In addition, other non-US governments have similar types of prohibited persons regulations that we must comply with.

7. What this means for Jones Lang LaSalle
Legislation requires us to have “adequate procedures” in place to ensure compliance
Establish comprehensive, best practice measures with respect to:
FCPA – Avoidance of “knowingly” making payments to foreign officials and to prevent them from exploiting their positions to gain unfair commercial advantage
UK Anti-Bribery act – Avoidance of making payments (both direct and indirect) to foreign officials in order to gain an improper advantage or to obtain or retain business
OFAC and other non-US Government Compliance – Screening of 3rd parties we do business with against prohibited persons lists

8. Measures We Have in Place to Comply
Enterprise risk management and due diligence commitment
Thomson Reuters Accelus Screening Online – comprehensive, global best practice measure to screen OFAC and similar prohibited persons lists
This program is an integral part of the enterprise risk management / due diligence commitment of each of Jones Lang LaSalle (JLL) and LaSalle Investment Management (LIM)
Board oversight and responsibility for anti-corruption program
Global policies and procedures, including gifts and hospitality policy
Corporate compliance, including Anti-Money Laundering / Know Your Customer (AML/KYC), Foreign Corrupt Practices Act (FCPA), UK Anti-Bribery Act, OFAC and other non-US government prohibited persons lists

9. Measures We Have in Place to Comply, cont’d
Ethics Everywhere Program
Code of Business Ethics
Vendor Code of Conduct
Ethics training, reporting and investigation procedures
Jones Lang LaSalle has been named one of the World’s Most Ethical Companies for 5 years in a row
Financial controls
Supply chain management
Employment procedures, including new hire background checks, compliance and training programs

10. Focus on Accelus – A Due Diligence Tool
JLL uses Accelus Screening Online to help us with OFAC and other governments prohibited persons lists
Accelus takes our data and that of our clients and screens it daily against global sanction and enforcement databases mitigating the risk of regulatory and reputational failure
Captures JLL / LIM global data from key internal sources (currently screen in excess of 850,000 vendor / client / tenant / landlord records daily)
Identification of new data sources is an ongoing process
Screens data against key global databases (see list in appendix)
Potential regulatory events are flagged by the legal team in each region
Events requiring action are reviewed with the JLL/LIM owner of that relationship and if required, the vendor/client/tenant/landlord details are added to a list of people/entities with whom we will no longer engage in business activities
Due to privacy laws in many countries, regulatory information is not able to be provided to JLL’s clients about their third party service providers

11. Thank you

12. Appendix Click on Jones Lang LaSalle’s website link for:
Ethics Everywhere (About Us, Ethics Everywhere)
Code of Business Ethics
Supply Chain Management / Vendor Code of Conduct in 17 languages
Other supporting documents are:
Anti-Money Laundering / Know Your Customer(AML / KYC)
JLL / Accelus Data Sources
(Note: to use the links above, you must view this presentation in slide show mode)