We are a responsible and ethical company, committed to the highest standards of governance. To that end, we have put the following policies into place to ensure that the highest standards are adhered to.
Further details on our governance framework, Board responsibilities, Committees and key policies are detailed in the Investor pages of our website.
Our policies include:
Protecting personal data is core to the Group’s operations. We invest heavily in data security and privacy controls and work hard to ensure our marketplaces, white labels and SaaS back-office solutions are safe to use, that the data we store is secure and that we comply with all applicable local and national data protection legislation.
We have undertaken both internal and external audits of our cyber security and data protection controls and continue to review and strengthen our processes and policies to meet the new threats that face online marketplaces, white labels and SaaS products. We have organisational and technical measures implemented across the Group to ensure that our services and data are protected. We undertake periodic analysis to identify potential vulnerabilities and risks. We have processes in place to quickly identify potential incidents and mitigate accordingly.
We have an internal governance framework for data protection and information security including various policies, procedures and training. Our policies are frequently reviewed and updated. All employees must certify that they have read and understood our core policies.
Further specialised policies and standards are required for employees in engineering, product and design. Our Data Protection Officer has extensive experience in cyber security and data privacy, data breach prevention and reporting, policy compliance, record keeping and data subject rights.
Card payments from bidders are handled by third-party suppliers on behalf of the Group and by auction houses clients. Online subscriptions to the Antiques Trade Gazette are managed in a similar fashion.
In accordance with anti-money laundering regulations, auction houses are required to conduct appropriate due diligence on any bidders spending more than €10,000 in any single transaction or series of linked transactions. We work closely with auction houses in order to support this process and assist with compliance. In particular, we have developed and continue to develop practicable procedures for bidders and auction houses to follow. Through our central platform, we are able to centralise this verification process for bidders, reducing friction across different marketplaces.
We have strict rules with regard to the listing of prohibited items on our marketplaces, such as offensive items, illegal arms, and illegal wildlife products, and we employ a compliance team to monitor adherence to these restrictions.
Full details of our restricted items policies can be found on each of our marketplace websites.
It is important that bidders can trust the buying experience on our marketplaces and that they know that auctioneers are following best practice. Auction houses wishing to list on our marketplaces must complete our application form to ensure they meet best practice standards. Equally it is important to auction houses that they are protected against fraudulent bidders. To this end we have bidder security teams dedicated to minimising the number of marketplace bidders who default on their purchases.
It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery and corruption.
We are committed to maintaining the highest standards of honesty, openness and accountability both within the organisation and in all its business dealings. ATG and its employees must behave honestly, and customers must be able to have absolute confidence in us. We recognise that employees have an important role to play in achieving these goals.
A whistleblowing policy has been adopted which includes access to a whistleblowing telephone service run by an independent organisation, allowing employees to raise concerns on a strictly confidential basis. The Audit Committee receives regular reports on the use of the service, and any issues that are raised, the findings of any investigations and any actions arising.
We are committed to improving our practices to ensure slavery and human trafficking are not taking place in any part of our business or our supply chain. We expect the same commitment from our suppliers, contractors and business partners. We will not tolerate the mistreatment of people in our employment and, wherever possible, employed in our supply chain. Our Modern Slavery Act Statement can be found here.
We are committed to supporting human rights through our compliance with national laws and through our internal policies which adhere to internationally recognised human rights principles. Our Code of Conduct and associated policies require respect and equal and fair treatment of all persons we come into contact with. We safeguard our employees through a framework of policies and statements in respect of equal opportunities and inclusion policies.
We take a responsible attitude to tax, recognising that it affects all our stakeholders. We seek at all times to comply with the law in each of the jurisdictions in which we operate, and to build open and transparent relationships with those jurisdictions’ tax authorities.