Management responsibilities

By the nature of their position and their opportunities, administrators, managers and directors have more responsibilities than other employees regarding the implementation of this Code of Ethics, as well as all company policy.

Administrators, managers and directors must:

- Follow to the letter the rules, policies and internal Sotheby’s® procedures and manage while providing a positive example.
- Create an atmosphere favorable to the rules, policies and internal Sotheby’s® procedures, and encourage employees to ask pertinent questions regarding rules, policies and procedures.
- Ensure that employees under their management are aware of rules, policies and internal Sotheby’s® procedures, and that they have received the correct training.
- Consider the employee’s compliance with rules, policies and internal Sotheby’s® procedures when evaluating and/or rewarding employees by means of salary, bonus or promotion.

Employee responsibilities

Employees must respect the fundamental obligations of this Code as well as those of company policy:

- Employees must learn the details of rules, policies and internal Sotheby’s® procedures applicable to their specific responsibilities. Each employee must have a basic understanding of questions relating to company policy and a detailed understanding of rules and regulations relating to the employee’s position.
- It is required to contact the director of compliance when an employee has questions regarding the signification or interpretation of a rule, policy or internal Sotheby’s® procedure.
- Employees must inform the director of compliance immediately if he/she is concerned about breaches, real or potential, to the rules, policies and internal Sotheby’s® procedures.
- Finally, employees must follow the training required regarding rules, policies and internal Sotheby’s® procedures.

Sanctions in the case of breach of rules, policies and internal procedures

Employees who breach the precise written details or the sense of this Code or company policy are subject to disciplinary measures, including termination of the employee’s position. Conduct that may lead to disciplinary measures include:
- Actions that breach this Code or company policy
- Asking others to breach this Code or company policy
- A failure to bring immediately to attention a known or suspected breach of this Code or company policy
- A failure to assist an enquiry regarding a possible breach of this Code or company policy.
- Retaliation against another employee for having brought to attention a breach of this Code or company policy
- A failure to apply sufficient effort in the application of the present Code or company policy, as well as applicable rules and regulations

Breaches of this Code or company policy may also be illegal and expose the individual or the company to criminal or civil proceedings.