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Anti-Competitive Conduct

Effective date: January 1, 2023

We are committed to upholding fair competition practices and complying with all relevant competition laws and regulations. Below, we outline key information about competition law, our meeting protocol, and our policy and process for reporting anti-competitive conduct or activities if discovered.

Competition law, also known as antitrust law, is designed to promote fair competition in the marketplace and prevent anti-competitive behavior that harms consumers, other businesses, and the overall economy. It prohibits practices such as price-fixing, bid-rigging, market allocation, and other forms of collusion that distort competition and restrict consumer choice. Compliance with competition law is essential to ensure a level playing field and foster innovation, efficiency, and consumer welfare.

Meeting Protocol
In our company, we recognize the importance of conducting meetings and discussions in a manner that complies with competition law and promotes fair competition. To ensure adherence to competition law principles, we follow a meeting protocol that includes the following guidelines:

  • Avoid discussing sensitive topics such as pricing, terms of trade, or market strategies with competitors.
  • Refrain from exchanging competitively sensitive information, including pricing, costs, sales volumes, or future business plans, with competitors.
  • Conduct meetings and discussions in a transparent and professional manner, focusing on legitimate business topics that do not raise competition law concerns.
  • Seek legal advice or guidance if uncertain about the legality of any proposed discussions or agreements with competitors.
  • By adhering to this meeting protocol, we demonstrate our commitment to fair competition practices and avoid engaging in any conduct that may violate competition law.

Policy and Process for Reporting Anti-competitive Conduct/Activities

Our company has established a clear policy and process for reporting any suspected or observed anti-competitive conduct or activities. We encourage employees, partners, and stakeholders to report such behavior promptly to ensure timely investigation and appropriate action. The reporting process includes the following steps:

  • Individuals who become aware of potential anti-competitive conduct or activities should report their concerns to the designated compliance officer or legal department.
  • Reports should include detailed information about the nature of the conduct, the parties involved, and any supporting evidence or documentation.
  • The compliance officer or legal department will promptly investigate the reported conduct in a fair, impartial, and confidential manner.
  • If the investigation confirms the existence of anti-competitive behavior, appropriate remedial actions will be taken to address the conduct and prevent recurrence.
  • In cases where the conduct may violate competition law, the company will cooperate fully with regulatory authorities and law enforcement agencies, including providing relevant information and assisting in investigations.

By establishing this policy and process, we demonstrate our commitment to maintaining a culture of integrity, compliance, and fair competition within our organization and the broader marketplace.
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