Code of Conduct

All rules here outlined should be followed when present on any Gallery 130 Inc. (herein “The Gallery” or “Gallery 130”) properties.

Who Must Follow Our Code?

We expect all of our employees and Board members to know and follow the Code. Failure to do so can result in disciplinary action, including termination of employment or separation. Moreover, while the Code is specifically written for Gallery 130 employees and Board members, we expect members of our extended workforce (temps, vendors, and independent contractors) and others who may be temporarily assigned to perform work or services for Gallery 130 to follow the Code in connection with their work for us. Failure of a member of our extended workforce or other covered service providers to follow the Code can result in termination of their relationship with Gallery 130.

No Retaliation


Gallery 130 prohibits retaliation against any worker here at Gallery 130 who reports or participates in an investigation of a possible violation of our Code, policies, or the law. If you believe you are being retaliated against, please contact Ethics & Compliance.

1 Serve Our Customers and Members


Our members value Gallery 130 not only because we provide valuable services, but because we hold ourselves to a higher standard in how we treat our members and customers and operate more generally. Keeping the following principles in mind will help us to maintain that high standard:

1.1 Integrity


Our reputation as a company that our members can trust is our most valuable asset, and it is up to all of us to make sure that we continually earn that trust. All of our communications and other interactions with our members should increase their trust in us.

1.2 Usefulness


Our products, features, and services should make Gallery 130 more useful for all our members. We have many different types of customers, from individuals to companies, artists to labels, but one guiding principle: “Is what we are offering useful?”

1.3 Privacy, Security, and Freedom of Expression


Always remember that we are asking members to trust us with their personal information and works. Preserving that trust requires that each of us respect and protect the privacy and security of that information. Our security procedures strictly limit access to and use of members’ personal information, and require that each of us take measures to protect member data from unauthorized access. Know your responsibilities under these procedures, and collect, use, and access member personal information only as authorized by our Security Policies, our Privacy Policies, and applicable data protection laws.

Gallery 130 is committed to advancing creativity and freedom of expression for our members around the world. Where freedom of expressions face government challenges, we seek to implement internationally recognized standards that respect those rights as we provide our services. Contact Legal or Ethics & Compliance if you have questions on implementing these standards in connection with what you do at Gallery 130.

1.4 Responsiveness


Part of being useful and honest is being responsive: We recognize relevant member feedback when we see it, and we do something about it. We take pride in responding to communications from our members, whether questions, problems, or compliments. If something is broken, fix it.

1.5 Take Action


Any time you feel our members aren’t being well-served, don’t be bashful - let someone in the company know about it. Continually improving our products and services takes all of us, and we are proud that The Gallery champion our members and take the initiative to step forward when the interests of our members are at stake.

2 Support and Respect Each Other

Our principles

Gallery 130 has an unwavering commitment to prohibiting and effectively responding to harassment, discrimination, misconduct, abusive conduct, and retaliation.

To that end, the Gallery adheres to these Guiding Principles:


Gallery 130 sets a tone at the top of commitment to a respectful, safe, and inclusive working environment for all employees and members of the extended workforce.


Gallery 130 creates an environment with an emphasis on respect for each individual at all levels of the organization, including specifically by offering assistance and showing empathy to employees and members of the extended workforce throughout and after the complaint process.


Gallery 130 is open and transparent as an organization regarding the frequency with which complaints arise regarding harassment, discrimination, misconduct, abusive conduct, and retaliation, and the Company’s approach to investigating and responding to those allegations.

Fairness & Consistency:

Gallery 130 ensures that individuals are treated respectfully, fairly, and compassionately in all aspects of Alphabet interactions and applies policies, procedures, and outcomes consistently regardless of who is involved.



Gallery 130 holds all individuals responsible for their actions, and ensures that where appropriate, those individuals hold others accountable too.

3 Equal Opportunity Employment


Employment here is based solely upon individual merit and qualifications directly related to professional competence. We strictly prohibit unlawful discrimination or harassment on the basis of race, color, religion, veteran status, national origin, ancestry, pregnancy status, sex, gender identity or expression, age, marital status, mental or physical disability, medical condition, sexual orientation, or any other characteristics protected by law. We also make all reasonable accommodations to meet our obligations under laws protecting the rights of the disabled.

4 Harassment, Discrimination, and Bullying


Gallery 130 prohibits discrimination, harassment and bullying in any form – verbal, physical, or visual, as discussed more fully in our Policy Against Discrimination, Harassment and Retaliation. If you believe you’ve been bullied, harassed, or discriminated against by anyone at Gallery 130, or by a Gallery 130 partner or vendor, we strongly encourage you to immediately report the incident to your supervisor, Human Resources or both. Similarly, supervisors and managers who learn of any such incident should immediately report it to Human Resources. Human Resources will promptly and thoroughly investigate any complaints and take appropriate action.

5 Drugs and Alcohol


Our position on substance abuse is simple: It is incompatible with the health and safety of our employees, and we don’t permit it. Consumption of alcohol is not banned at our offices, but use good judgment and never drink in a way that leads to impaired performance or inappropriate behavior, endangers the safety of others, or violates the law. Illegal drugs in our offices or at sponsored events are strictly prohibited. If a manager has reasonable suspicion to believe that an employee’s use of drugs and/or alcohol may adversely affect the employee’s job performance or the safety of the employee or others in the workplace, the manager may request an alcohol and/or drug screening. A reasonable suspicion may be based on objective symptoms such as the employee’s appearance, behavior, or speech.

6 Safe and Healthy Workplace


We are committed to a safe, healthy, and violence-free work environment. Behavior that poses risk to the safety, health, or security of Members and Employees, our extended workforce, or visitors is prohibited. If you become aware of a risk to the safety, health, or security of our workplace, you should report it to Ethics & Security immediately. If it is life-threatening or an emergency, call your local police, fire, or other emergency responders first, and then report it to Ethics & Security.

7 Avoid Conflicts of Interest


When you are in a situation in which competing loyalties could cause you to pursue a personal benefit for you, your friends, or your family at the expense of Gallery 130 or our members, you may be faced with a conflict of interest. All of us should avoid conflicts of interest and circumstances that reasonably present the appearance of a conflict.

When considering a course of action, ask yourself whether the action you’re considering could create an incentive for you, or appear to others to create an incentive for you, to benefit yourself, your friends or family, or an associated business at the expense of Gallery 130. If the answer is “yes,” the action you’re considering is likely to create a conflict of interest situation, and you should avoid it.

Below, we provide guidance in seven areas where conflicts of interest often arise:

  • Personal investments

  • Outside employment, advisory roles, board seats, and starting your own business

  • Business opportunities found through work

  • Inventions

  • Friends and relatives; co-worker relationships

  • Accepting gifts, entertainment, and other business courtesies

  • Use of Gallery 130 products and services

In each of these situations, the rule is the same – if you are considering entering into a business situation that creates a conflict of interest, don’t. If you are in a business situation that may create a conflict of interest, or the appearance of a conflict of interest, review the situation with your manager and Ethics & Compliance. Finally, it’s important to understand that as circumstances change, a situation that previously didn’t present a conflict of interest may present one.

8 Personal Investments


Avoid making personal investments in companies that are Gallery 130 competitors or business partners when the investment might cause, or appear to cause, you to act in a way that could harm Gallery 130.

When determining whether a personal investment creates a conflict of interest, consider the relationship between the business of the outside company, Gallery 130’s business, and what you do at The Gallery, including whether the company has a business relationship with Gallery 130 that you can influence, and the extent to which the company competes with Gallery 130. You should also consider 1) any overlap between your specific role at Gallery 130 and the company’s business, 2) the significance of the investment, including the size of the investment in relation to your net worth, 3) whether the investment is in a public or private company, 4) your ownership percentage of the company, and 5) the extent to which the investment gives you the ability to manage and control the company.

9 Outside Employment, Advisory Roles, Board Seats, and Starting Your Own Business


Avoid accepting employment, advisory positions, or board seats with Gallery 130 competitors or business partners when your judgment could be, or could appear to be, influenced in a way that could harm Gallery 130. Additionally, because board seats come with fiduciary obligations that can make them particularly tricky from a conflict of interest perspective, you should notify your manager before accepting a board seat with any outside company. Gallery 130 board members and employees who are VP and above should also notify Ethics & Compliance. Finally, do not start your own business if it will compete with Gallery 130.

10 Business Opportunities Found Through Work


Business opportunities discovered through your work here belong first to Gallery 130, except as otherwise agreed to by Gallery 130.

11 Inventions


Developing or helping to develop outside inventions that a) relate to The Gallery’s existing or reasonably anticipated products and services, b) relate to your position at Gallery 130, or c) are developed using Gallery 130 corporate resources may create conflicts of interest and be subject to the provisions of Gallery 130’s Confidential Information and Invention Assignment Agreement and other employment agreements. If you have any questions about potential conflicts or intellectual property ownership involving an outside invention or other intellectual property, consult Ethics & Compliance or Legal.

12 Personal Relationships at Work


Certain relationships within Gallery 130 may compromise or be seen to compromise your ability to perform your job responsibilities, may create uncomfortable or conflicted positions, and may raise issues of fairness, favoritism, or harassment. Therefore, be mindful of how your relationships within Gallery 130 could impact or be perceived by others. Romantic, physical or familial relationships are not permitted between an employee and another employee or member of the extended workforce where one individual is in a position to exercise authority or supervision over the other. This prohibition includes any situation where one person is in the reporting line of the other, or, for example, a situation where one person is a project or a technical lead on a project on which the other person is working. For questions on relationships at work, contact Human Resources.

13 Accepting Gifts, Entertainment, and Other Business Courtesies


Accepting gifts, entertainment, and other business courtesies from a Gallery 130 competitor or business partner can easily create the appearance of a conflict of interest, especially if the value of the item is significant. Gallery 130’s policy provides specific guidance on when it is appropriate for employees to accept gifts, entertainment, or any other business courtesy (including discounts or benefits that are not made available to all employees) from any of our competitors or business partners.

Generally, acceptance of inexpensive “token” non-cash gifts is permissible. In addition, infrequent and moderate business meals and entertainment with clients and infrequent invitations to attend local sporting events and celebratory meals with clients can be appropriate aspects of many Gallery 130 business relationships, provided that they aren’t excessive and don’t create the appearance of impropriety. Before accepting any gift or courtesy, consult the policy, and be aware that you may need to obtain manager approval.

Contact Ethics & Compliance if you have any questions. See the discussion of Anti-Bribery Laws in Section VII(d) for guidance on when it is appropriate to give gifts and business courtesies in the course of doing Gallery 130 business.

14 Reporting


Ethics & Compliance will periodically report to the Gallery 130 Compliance Steering Committee all matters involving Gallery 130 officers – VPs and above – approved under this section of the Code, and will periodically report to the Gallery 130 Nominating and Corporate Governance Committee all matters involving Gallery 130 executive officers and Board members approved under this section.

15 Preserve Confidentiality


We get a lot of press attention around our innovations and our culture, and that’s usually fine. However, certain kinds of company information, if leaked prematurely into the press or to competitors, can hurt our product launches, eliminate our competitive advantage and prove costly in other ways. Our responsibilities extend beyond not revealing Confidential Gallery 130 material – we must also:

  • properly secure, label, and (when appropriate) dispose of Confidential Gallery 130 material;

  • safeguard Confidential information that Gallery 130 receives from others under non-disclosure agreements;

  • take steps to keep our trade secrets and other confidential intellectual property secret.

16 Confidential Information


Make sure that information that is classified as “Need to Know” or “Confidential” in the Data Classification Guidelines is handled in accordance with those Guidelines and the Data Security Policy. At times, a particular project or negotiation may require you to disclose Need to Know or Confidential information to an outside party: Disclosure of that information should be on an “only as needed” basis and only under a non-disclosure agreement. In addition, Gallery policy may require a prior security assessment of the outside party that is to receive the confidential information. Be sure to conduct the appropriate due diligence and have the appropriate agreement in place before you disclose the information.

There are, of course, “gray areas” in which you will need to apply your best judgment in making sure you don’t disclose any confidential information. If you’re in a gray area, be cautious in what advice or insight you provide or, better yet, ask for guidance from Ethics & Compliance.

And don’t forget about pictures you and your guests take at Gallery 130 – it is up to you to be sure that those pictures don’t disclose confidential information.

Finally, some of us will find ourselves having family or other personal relationships with people employed by our competitors or business partners. As in most cases, common sense applies. Don’t tell your significant other or family members anything confidential, and don’t solicit confidential information from them about their company.

17 Outside Communications


You probably know that our policy is to be extremely careful about disclosing confidential proprietary information. Consistent with that, you should also ensure your outside communications (including online and social media posts) do not disclose confidential proprietary information or represent (or otherwise give the impression) that you are speaking on behalf of Gallery 130 unless you’re authorized to do so by the company. The same applies to communications with the press. Finally, check with your manager and Corporate Communications before accepting any public speaking engagement on behalf of the company. In general, before making any external communication or disclosure, you should consult our Employee Communications Policy and our Communications and Disclosure Policy.

18 Intellectual Property


Gallery 130’s intellectual property rights (our trademarks, logos, copyrights, trade secrets, “know-how”, and patents) are among our most valuable assets. Unauthorized use can lead to their loss or serious loss of value. You must respect all copyright and other intellectual property laws, including laws governing the fair use of copyrights, trademarks, and brands. You must never use Gallery 130 (or its affiliated entities’) logos, marks, or other protected information or property for any business or commercial venture without pre-clearance from the Marketing Team. We strongly encourage you to report any suspected misuse of trademarks, logos, or other Gallery 130 intellectual property to Legal.

Likewise, respect the intellectual property rights of others. Inappropriate use of others’ intellectual property may expose Gallery 130 and you to criminal and civil fines and penalties. Please seek advice from Legal before you solicit, accept, or use proprietary information from individuals outside the company or let them use or have access to Gallery 130 proprietary information. You should also check with Legal if developing a product that uses content not belonging to Gallery 130.

19 Company Equipment


Gallery 130 gives us the tools and equipment we need to do our jobs effectively, but counts on us to be responsible and not wasteful with the Gallery 130 stuff we are given. Nobody’s going to complain if you snag an extra bagel on Friday morning, but company funds, equipment, and other physical assets are not to be requisitioned for purely personal use. Not sure if a certain use of company assets is okay? Please ask your manager or Human Resources.

20 The Network


Gallery 130’s communication facilities (which include both our network and the hardware that uses it, like computers and mobile devices) are a critical aspect of our company’s property. sure to follow all security policies. If you have any reason to believe that our network security has been violated – for example, you lose your laptop or smart phone or think that your network password may have been compromised – please promptly report the incident to Information Security. For more information, consult Gallery 130’s Security Policy.

21 Physical Security


If you’re not careful, people may steal your stuff. Always secure your laptop, important equipment, and your personal belongings, even while on Gallery 130’s premises. Always wear your badge visibly while on site. Don’t tamper with or disable security and safety devices. If you see someone in a secure space without a badge, report that, and any other suspicious activity, to Security. For more information, review Physical Security Policy or ask Security.

22 Use of Equipment and Facilities


Anything you do using Gallery 130’s corporate electronic facilities (e.g., our computers, mobile devices, network, etc.) or store on our premises (e.g., letters, memos, and other documents) might be disclosed to people inside and outside the company. For example, Gallery 130 may be required by law (e.g., in response to a subpoena or warrant) to monitor, access, and disclose the contents of corporate email, voicemail, computer files, and other materials on our electronic facilities or on our premises. In addition, the company may monitor, access, and disclose employee communications and other information on our corporate electronic facilities or on our premises where there is a business need to do so, such as protecting employees and users, maintaining the security of resources and property, or investigating suspected employee misconduct.

23 Employee Data


We collect and store personal information from employees around the world. Access this data only in line with local law and Gallery 130 internal policies, and be sure to handle employee data in a manner that is consistent with Gallery 130’s Data Classification and Employment Data Guidelines and other Gallery 130 policies.

23.1 Ensure Financial Integrity and Responsibility


Financial integrity and fiscal responsibility are core aspects of corporate professionalism. This is more than accurate reporting of our financials, though that’s certainly important. The money we spend on behalf of Gallery 130 is not ours; it’s the company’s and, ultimately, our shareholders’. Each person at Gallery 130 – not just those in Finance – has a role in making sure that money is appropriately spent, our financial records are complete and accurate, and internal controls are honored. This matters every time we hire a new vendor, expense something to Gallery 130, sign a new business contract, or enter into any deals on Gallery 130’s behalf.

To make sure that we get this right, Gallery 130 maintains a system of internal controls to reinforce our compliance with legal, accounting, tax, and other regulatory requirements in every location in which we operate.

Stay in full compliance with our system of internal controls, and don’t hesitate to contact Ethics & Compliance or Finance if you have any questions. What follows are some core concepts that lie at the foundation of financial integrity and fiscal responsibility here at Gallery 130.

24 Hiring Suppliers


As Gallery 130 grows, we enter into more and more deals with suppliers of equipment and services. We should always strive for the best possible deal for Gallery 130. This almost always requires that you solicit competing bids to make sure that you’re getting the best offer. While price is very important, it isn’t the only factor worth considering. Quality, service, reliability, and the terms and conditions of the proposed deal may also affect the final decision. Please do not hesitate to contact the Purchasing Team if you have any questions regarding how to procure equipment or services.

25 Retaining Records


It’s important that we keep records for an appropriate length of time. The Gallery 130 Records Retention Policy suggests minimum record retention periods for certain types of records. These are great guidelines, but keep in mind that legal requirements, accounting rules, and other external sources sometimes specify longer retention periods for certain types of records, and those control where applicable. In addition, if asked by Legal to retain records relevant to a litigation, audit, or investigation, do so until Legal tells you retention is no longer necessary. If you have any questions regarding the correct length of time to retain a record, contact the Records Retention Team.

26 Obey the Law


Gallery 130 takes its responsibilities to comply with laws and regulations very seriously and each of us is expected to comply with applicable legal requirements and prohibitions. While it’s impossible for anyone to know all aspects of every applicable law, you should understand the major laws and regulations that apply to your work. Take advantage of Legal and Ethics & Compliance to assist you here. A few specific laws are easy to violate unintentionally and so are worth pointing out here:

  • Trade Laws

  • Anti-corruption laws

  • Anti-bribery laws

  • Competition laws

  • Corruption laws


Strive to do right, respect each other, treat and bring concerns to leadership or a respective department.