Sotheby's responsibility for internal policies and procedures

Numerous laws, rules and regulations apply to Sotheby's® across the globe. A significant challenge for employees who must understand how these laws, rules and regulations apply to our business activities. We are bound to obey all laws, rules and regulations determining our business conduct.

In the case of uncertainty regarding these laws, rules and regulations, advice and guidance must be obtained from management, legal or compliance teams.

Equal treatment

We are bound to treating our clients, our suppliers, our competitors and other employees equitably. No one may unjustly profit from another by means of manipulation, concealment, abusive use of privileged information, false representation of facts, or any other disloyal action.

This requirement for equal treatment does not in any way modify the rights and legal obligations of Sotheby's® and its employees.

Conflicts of interest

A “conflict of interest” occurs if or when a person’s personal interest enters into conflict or interferes in any way– or appears to enter into conflict or interfere in any way – with the interest of Sotheby's®. A conflictual situation may arise when an employee undertakes actions or has interests that may hinder him/ her in the objective and efficient execution of his/ her functions with Sotheby's®. Conflicts of interest may also occur if or when an employee, or a member of his/her family, benefits from unjustified personal advantages thanks to his/her position with Sotheby's®.

We are bound to adhere to company policy regarding the purchase and sale of assets with Sotheby's® as an intermediary, and to also avoid actions and relationships that may lead to conflict or appear to lead to conflict with our professional responsibilities or with the interests of Sotheby's®. Through appropriate analysis, most conflicts of interest or apparent conflicts of interest may be managed and controlled without negative consequences or having any impact on the integrity of Sotheby's® or of the persons concerned. Potential conflicts of interest should be reported immediately to the global director of compliance. Business opportunities

Employees have a duty to the business to promote the legitimate interests of Sotheby's® whenever the opportunity arrives: Consequently, it would be inappropriate for employees to:

- Use Sotheby's® work tools, information or their position for personal gain.
- To directly or indirectly compete with Sotheby's®.
- To take decisions or undertake actions contrary to the interests of Sotheby's®.

Confidentiality

We are bound to maintain confidentiality and to respect the exclusive character of information entrusted by Sotheby's® or by their clients, except when disclosing this information is authorized or legally mandated. Confidential information includes all information unavailable to the general public which could be of use to competitors or be detrimental to Sotheby's® or their clients if disclosed.