Responsible AI Statement

At JLL, we are committed to the ethical and responsible use of Artificial Intelligence (AI) that aligns with our Code of Ethics and respects the rights and dignity of individuals, including nondiscrimination, privacy, and fair treatment in our business practices. We believe AI has the power to create significant value for our clients, employees, and communities, but we recognize that it must be guided by a strong ethical compass.

This Commitment documents JLL's responsible AI use principles, outlining the key practices and governance structures that ensure our AI initiatives are developed and used in a manner consistent with JLL's values and applicable laws. It should be read alongside JLL's Generative AI Responsible Use Guidelines, Code of Ethics, and related corporate policies.

• Fairness and non-discrimination: Consistent with JLL's Code of Ethics and our commitment to treating everyone with dignity and respect, we govern our AI systems to minimize and actively monitor for bias and discriminatory outcomes. We work to identify and mitigate potential bias in our AI use practices, with particular attention to personal characteristics protected under applicable laws and regulations in the jurisdictions where we operate. Where bias or discriminatory outcomes are identified, we take prompt corrective action. We recognize this as an ongoing responsibility and commit to the continuous evaluation and improvement of our AI systems to uphold these standards.
• Transparency and explainability: We strive to make our AI systems transparent and understandable to the extent possible. Where practical, we provide clear, accessible explanations of how our AI systems work and make decisions, particularly when those decisions affect individuals or stakeholders. When AI materially informs client-facing recommendations or deliverables, we are committed to appropriate transparency regarding its role. 
• Accountability and responsibility: We take responsibility for the impact of our AI systems. We establish clear lines of accountability for the use of AI and have governance structures and mechanisms in place to address any unintended consequences or harms that may arise. 
• Privacy and data protection: We are committed to protecting the privacy and security of personal data used in our AI systems. We comply with applicable data protection laws and regulations and adhere to the standards of data governance for responsible and transparent management of personal information.
• Security and safety: We embed security and safety into our use of AI systems, adhering to JLL's corporate policies. Our systems undergo testing and monitoring to protect against unintended consequences, misuse, and cyber threats while ensuring they do not pose risks to human safety.
• Human oversight and control: We believe that human oversight is essential for responsible AI. We ensure human oversight in AI decision-making processes, particularly when decisions have significant implications for individuals, and maintain human guidance for final decisions and regulatory compliance.

To uphold these principles, we commit to the following key practices:

• AI committee: We maintain an AI Committee whose structure, authority, and meeting cadence are detailed in the Governance and Accountability section below.
• AI impact assessments: We conduct AI Impact Assessments to identify and address potential risks for AI systems that materially affect individuals, client outcomes, or regulatory compliance. This process incorporates fairness review and creates accessible documentation explaining how our AI systems function and are used. 
• Data governance and privacy framework: We adhere to a data governance and privacy framework that ensures data quality, integrity, security, and compliance with all applicable data protection laws and regulations.
• Employee training and partner awareness programs: We provide ongoing training and awareness programs to educate our employees on responsible AI principles, best practices, and evolving ethical standards and regulations. We also ensure that relevant partners and contractors operating within JLL's AI ecosystem are familiar with our responsible AI standards and expectations.
• Monitoring and auditing: We monitor and audit our AI systems to ensure they are performing as intended and in accordance with our corporate policies and applicable laws.
• Stakeholder engagement: We engage with stakeholders, including clients and employees, to gather feedback and ensure that our AI practices are aligned with their needs and expectations. Employees and stakeholders who have concerns about JLL's AI practices or outcomes are encouraged to raise them through JLL's existing reporting channels, including the Ethics Everywhere Helpline.
• Commitment to improvement: We are committed to continuously evaluating and improving our responsible AI practices in response to new laws, evolving best practices, and stakeholder feedback. We actively monitor developments under applicable AI regulations — including the EU AI Act and other emerging global frameworks — to ensure our practices remain current and compliant. This Commitment is reviewed and updated no less than annually, or sooner upon significant regulatory or technological change.

JLL’s AI Committee provides formal oversight and strategic direction for all AI initiatives. Chaired by JLL's Head of AI, the Committee comprises executive and operational members from key functions including technology, legal, security, privacy, and relevant business areas. The Committee meets regularly to oversee AI systems, assess risks, and ensure compliance with applicable legal requirements. Decisions follow a risk-based approach, with material matters escalated to senior leadership. Key decisions are documented to ensure accountability and transparency.