The purpose of the policy is to ensure Company compliance with federal and state antitrust laws, and, where applicable, foreign antitrust rules. Antitrust laws are designed to preserve and foster fair and honest competition within the free enterprise system.
It is the policy of the Company that all employees of the Company shall conduct Company business in compliance with all applicable antitrust laws. No employee has the authority to engage in any conduct inconsistent with applicable antitrust laws, nor to authorize or direct such conduct by any other person.
A) Agreements among Competitors. Employees of the Company shall not engage in any communications with competitors which may unreasonably restrain trade (e.g., price-fixing or bid-rigging).
B) Agreements with Suppliers, Distributors, and Customers. Employees of the Company shall not enter into "anticompetitive" agreements with or among suppliers, distributors, or customers. Agreements fixing resale prices are generally considered to be illegal per se and do not require that an anticompetitive effect be demonstrated.
C) Monopolization. It is the policy of the Company to comply with applicable antitrust laws which prohibit any person, acting alone or with others, from monopolizing or attempting to monopolize any part of trade or commerce.
D) General Guidance. In general, employees of the Company should avoid conduct that is directed toward damaging, injuring, or excluding competitors, or increasing market share for the purpose of gaining power over or monopolizing a market. Instead, the Company should focus its activities on expanding its business by providing the best products and services it can at competitive prices. Arrangements with customers, distributors, and suppliers should be based on promoting efficiency by decreasing cost and improving the quality of the goods or services provided.
Any employee who has questions about the application of the antitrust laws to past, present or future conduct is encouraged to consult with the Legal Department.
