HUMAN RESOURCES

INVESTIGATIONS OF LEGAL AND ETHICAL MISCONDUCT

EFFECTIVE DATE: November 2012

I. POLICY

A. This policy applies to all investigations by CBRE Limited, referred to herein as “CBRE” or “the Company,” of allegations or occurrences of legal and ethical misconduct (including fraud) or serious violations of company policies (including the Standards of Business Conduct) relating to the Company’s operations in Canada.

B. The objective of the Company’s Ethics and Compliance Program is;

1. To prevent and detect violations of not only the law, but also violations of internal policies and general business standards; and

2. To prevent situations and events from occurring that could have a negative impact on the Company’s clients, workforce and/or reputation, or,

3. Are otherwise in conflict with the Company’s values as set forth in the Standards of Business Conduct.

C. The Investigation Policy is a part of the Company’s Ethics and Compliance Program and is intended to establish the policies for investigating violations of the Standards of Business Conduct.

D. The Company’s Chief Compliance Officer shall administer and oversee the Company’s Ethics and Compliance Program and this investigation policy.

II. PROVISIONS AND CONDITIONS

A. All reported claims of legal or ethical misconduct (including fraud), or serious violations of Company policy (“serious misconduct”) shall be thoroughly, promptly and impartially investigated.

B. The Company shall take all appropriate actions deemed necessary in response to such

claims or occurrences of serious misconduct and investigations will be conducted in a manner that treats those affected with dignity and fairness.

C. All records of investigations shall be retained in compliance with applicable laws.

III. PROCEDURES

A. Reporting Serious Misconduct

1. An employee who has information concerning possible serious misconduct, is encouraged to report the facts relating to the alleged

HUMAN RESOURCES

INVESTIGATIONS OF LEGAL AND ETHICAL MISCONDUCT

EFFECTIVE DATE: November 2012

serious misconduct to one of the following several avenues for making such reports. These avenues for filing a report are specified in the Company’s Standards of Business Conduct and include:

a. The employee’s direct Manager; b. Any member of the Senior Management Team (Managing Director level or above); c. HR Service Center Canada (HRSC) at (866) 388-4346; d. Any member of the Human Resources or Legal Departments; e. The Company’s Chief Compliance Officer; or f. The CBRE HelpLine at (800) 799-6523 (see Section B, below, for additional information).

2. A Company manager (an employee with direct management responsibilities for other employees, including the power to hire and terminate employees, or an employee who is deemed to be a “manager” with reporting responsibilities under applicable law), who has information regarding possible serious misconduct must make a report to either:

a. Any member of the Human Resources or Legal Departments; or b. The Company’s Chief Compliance Officer.

3. Although it is not required, employees are encouraged to consider raising their concerns about inappropriate conduct, other than serious misconduct, using normal management channels, such as their supervisor or the executive in charge of their Business Unit. However, if an employee does not feel comfortable taking such actions, or feels that this approach would not or did not work, the employee is urged and encouraged to make a report through one of the reporting avenues listed in Section III.A above.

B. CBRE Ethics HelpLine

1. In addition to being one of the reporting avenues to make a report of serious misconduct, the CBRE Ethics HelpLine (“HelpLine”) is also available for employees who need assistance in resolving other ethical or compliance issues. 2. The Help Line includes both a confidential telephone number and a confidential mailbox, both of which are managed by the Company’s third- party outsourced service provider, Ethics Point, 24 hours per day, 7 days per week:

HUMAN RESOURCES

INVESTIGATIONS OF LEGAL AND ETHICAL MISCONDUCT

EFFECTIVE DATE: November 2012

Toll-free Helpline: 800-799-6523 E-mail address: ChiefComplianceOfficer@CBRE.com Web address: www.ethicspoint.com 3. Inquiries or reports made to the HelpLine may be made anonymously, but should be made in good faith. All information furnished will be kept confidential to the extent possible. 4. An Ethics Point communication specialist will perform the initial HelpLine intake and will classify the call based on a proprietary reporting system. Subject matter experts will be consulted as required. Complex or serious matters will be escalated to the appropriate management level. Every effort will be made to properly resolve all issues raised in each report. C. Notification 1. Upon receipt of a report by any of the reporting avenues, the Report must immediately being forwarded to either (i) any member of the

Human Resources or Legal Departments; and (ii) the Company’s Chief Compliance Officer.

2. If a report raises issues regarding accounting, audit or internal control, or any other matter covered by Section 301 of the Sarbanes Oxley Act of 2002, the person receiving the report must immediately notify and forward a copy of the Report to the Chief Compliance Officer, who in turn, will notify the Chair of the Audit Committee of the Board of Directors. At the discretion of the Chief Compliance Officer, other departments including Human Resources, Internal Audit and Legal, may be notified of the Report.

C. Initial Evaluation of the Report

1. Legal, Human Resources and/or the Chief Compliance Officer shall make an initial evaluation of each report received to determine the appropriate actions to be taken in order to investigate the report of misconduct or unethical behavior.

2. If the allegations in the Report are determined to involve the risk of

significant legal consequences or significant ethical conduct violations or fraud, the Report must be immediately referred to the Chief Compliance Officer who shall then determine:

a. The actions that the Company should take, including the nature

of any legal advice that the Company may require concerning the matter; and

b. The identity of the individual(s) – whether inside or outside of the Company -- to conduct the investigation.

HUMAN RESOURCES

INVESTIGATIONS OF LEGAL AND ETHICAL MISCONDUCT

EFFECTIVE DATE: November 2012

3. If the allegations in the report call into question the conduct or actions of the Chief Compliance Officer or a member of the Legal Department, the matter shall be referred immediately to the CEO or the Chair of the Audit Committee and outside counsel shall be selected to conduct the investigation and provide legal advice to the Company.

4. If the allegations in the report do not involve the risk of significant legal consequences or significant ethical conduct violations or fraud, Legal

And Human Resources shall make the initial evaluation of the Report and determine who should undertake the investigation. In most cases, the investigation should be conducted by Human Resources

D. Investigation

1. If a Report is made to one of the Reporting Avenues, specified above, the Company will promptly conduct a thorough and impartial investigation in accordance with this investigation policy.

2. Under no circumstances should the investigator have been involved in the alleged misconduct – either directly or indirectly.

3. In most cases, the investigator will prepare a written report of the results of the investigation and set forth any proposed corrective action and/or employee discipline.

F. Corrective Action and Discipline 1. The investigator may propose appropriate remedial measures, corrective action and/or discipline to be imposed. 2. The appropriate member of Senior Management shall make the final

decision on the appropriate remedial measures and the discipline to be imposed, if any.

a. The remedial measures can include taking appropriate steps or

sanctions: (i) to stop any material violations that are ongoing, (ii) to prevent any material violation that has yet to occur, and (iii) to remedy or otherwise appropriately address any material

violation that has already occurred and to minimize the likelihood of its recurrence.

b. Discipline may include a written reprimand, remedial education,

monetary penalties, suspension, and/or termination of employment.