Code of conduct

1. Honesty, integrity and fair play

The company and its staff are fully committed to the principle of honesty, integrity and fair play in the delivery of services and goods. Staff handle business operations, service applications, procurement and recruitment openly, fairly and impartially. This code applies to every employee, including temporary and part-time staff.

2. Equal opportunity

Auction Experts is an equal opportunity employer. Decisions on recruiting, hiring, training, assignment, promotion, transfer, termination and compensation are made regardless of race, colour, sex, religion, national origin, age, disability or any other protected status.

3. Safety and health

The company is committed to an injury-free and illness-free workplace, operated in an environmentally sound manner and in compliance with the laws that protect worker safety and the environment. Every employee is expected to perform their work safely.

4. Fair competition

Anticompetitive practices are prohibited. Employees do not agree with competitors on pricing, production limits, market sharing or sham tenders; do not misappropriate clients; do not poach employees to capture business; and take no action that harms consumers or violates competition law.

5. Governance and anti-corruption

The company has zero tolerance for corruption. Employees may not offer anything of value to government officials or business partners to obtain an undue advantage. Third-party contractors must work for reasonable, documented fees and comply with company policy.

6. Financial reporting

Every transaction is recorded so that clear financial statements can be prepared in conformity with generally accepted accounting principles. False entries are prohibited, no undisclosed funds or assets may be established, and every payment requires supporting documentation.

7. Restrictive agreements with third parties

Employees do not violate restrictive agreements with previous employers, and do not use or disclose confidential information or trade secrets obtained in previous employment.

8. Government contracts and services

The company complies with all applicable law on government contracts, and ensures that reports, certifications and declarations to government officials are accurate and complete.

9. Acceptance of advantages

Staff do not solicit or accept advantages from business contacts without the ethics officer's permission. A gift under €10 may exceptionally be accepted where refusal would be impolite; any other gift requires the ethics officer's written consent within five days. The officer keeps a record of the applicant, the occasion, the nature and value of the gift, and how it was disposed of.

10. Conflict of interest

A conflict arises when a staff member's private interests compete with the company's — financial interests, family connections, personal friendships or social obligations. Staff avoid using their position for personal benefit, avoid even the appearance of conflict, and declare actual or perceived conflicts to the ethics officer in writing.

11. Misuse of official position

Staff who misuse their official position for personal gain, or to favour relatives or friends, are liable to disciplinary action or prosecution. Favouring a relative's company as a supplier and leaking proprietary information are both examples.

12. Classified and proprietary information

Staff do not disclose classified or exclusive information to anybody without authorisation. Whoever controls such information provides adequate safeguards against its abuse or misuse; unauthorised disclosure of personal data may also breach privacy legislation.

13. Company property

Staff with access to company property use it properly, for business purposes. Misappropriation of property for personal use or resale is strictly prohibited.

14. Outside employment

An employee seeking paid work outside the company first obtains written, dated and signed permission from the ethics officer. Permission is withheld where the work conflicts with the company's interests and values.

15. Compliance with the code

It is the personal responsibility of every staff member to understand and comply with this code, and all staff sign a declaration of principle. Senior employees ensure the people reporting to them understand it. The questions to ask before acting: Is it company policy? Is it legal? What would colleagues think? Would I tell others? How would clients react? Would this survive being reported in a newspaper? What is the environmental impact?

16. Sanctions

The company takes prompt and appropriate remedial action in response to violations. The ethics officer analyses the complaint, hears the people involved, establishes the facts and issues a written decision stating the facts, the violation and the motivation. Sanctions range from a warning or reprimand to transfer, suspension or termination; fines range from one-fifth to five times a monthly salary. Serious violations are reported to the authorities.

17. Reporting

Employees have a responsibility to promptly report any violation of the code. The company provides confidential channels to the ethics officer, and no employee will be disciplined or retaliated against in any way for reporting a violation in good faith. Retaliation itself must be reported to the ethics officer immediately.

18. The ethics officer

An ethics officer is appointed — an external professional where the company's size requires it — chosen for trust, independence and competence in compliance matters. The officer receives and investigates concerns, interprets the code, provides guidance, and reports periodically on how effectively the code is working.

Appendix 1 — what counts as an advantage

An advantage includes gifts, loans, fees, rewards, commissions, valuable securities, property, offices, employment, contracts, releases of payment, services, favours and protection from penalties — and any offer or promise of one. Employees commit to not soliciting bribes directly or indirectly, not accepting travel expenses unrelated to business, not offering party donations, not accepting personal discounts that are not generally available, not accepting excessive meals or entertainment, ensuring no gift could appear to improperly influence its recipient, and raising any doubt with the ethics officer.

Appendix 2 — how gifts are disposed of

Perishable gifts are shared across the office or during company activities. Useful items go to charities, historical items to libraries or museums, display items stay on company premises. A personal item under €100 may be retained by the recipient.

Appendix 3 — examples of conflict of interest

A staff member holding a financial interest in a company under consideration as a supplier is in a conflict situation. So is a staff member who accepts frequent gifts from suppliers or contractors.

Questions about this code

Questions and reports go to info@auction-experts.com or +31 (0)6 82047260 — Logan ICT Services B.V., Overhoeksplein 3, 1031 KS Amsterdam, the Netherlands.