Protection of confidential data

Theft, negligence and wastage have a direct impact on the activities of Sotheby's®. We must protect company assets and ensure their efficient use. All company assets must be used to achieve legitimate sales or authorized ancillary aims.
Insider trading

If we are in possession of material information unknown to the general public regarding Sotheby's® (or any other company with whom we work), it is prohibited to use or share this information in any way other than in-company in order to conduct our business activity.

Owing to the nature of their post and their work, all or our administrators are subject to further restrictions regarding the negotiation of company shares. Each has been and shall continue to be informed about this status and restrictions relating to it.

Public Disclosure

Sotheby's® is a public company and is bound by laws and regulations to file certain reports and to communicate certain information; these must be complete, exact, accurate, opportune and comprehensible. Sotheby's® also demands the same information criteria to take business decisions. All books, registers, accounts, balance sheets and information must be prepared in compliance with our internal control system interne, must reflect in an appropriate manner the company’s business transactions, and must be in conformity with applicable legal requirements.

Employees are prohibited from taking actions, directly or indirectly, in order to influence, force, manipulate or mislead Sotheby's® independent auditors with the intention of making the Sotheby's balance sheet appear inexact.

Drawing attention to conduct that is illegal or unethical

If a person becomes aware of anything that may be considered as fraudulent or illegal, or of any potentially inappropriate question regarding bookkeeping, internal controls of accounts or audit at Sotheby's®, or learns of any other breach of this Code, this person must report the situation to a supervisor (24/7 free telephone service, 1-800-738-3051)

If a person does not know if the conduct of a third party is illegal, contrary to the Code of Ethics or to company policy, he/she is encouraged to discuss with a supervisor or a superior regarding the best way to proceed.

If a breach is notified, all possible efforts shall be made to keep the identity of the informant confidential. It is also Sotheby's® policy to prohibit retaliation against persons who, in good faith, draw attention to real or apparent breaches of the Code of Ethics or company policy. If you require an internal enquiry regarding misconduct or breach of this Code of Ethics or company policy, your co-operation is solicited.