ANTITRUST COMPLIANCE
SAS is committed to full compliance with all laws and regulations, and to maintaining the highest ethical standards in the way we conduct our operations and activities. Our commitment includes strict compliance with federal and state antitrust laws, which are designed to protect this country’s free market competitive economy.
Responsibility for Antitrust Compliance
Compliance with the antitrust laws is a serious business. Antitrust violations may result in heavy fines for corporations, and in fines and even imprisonment for individuals. While your counsel can provide guidance on antitrust matters, you bear the ultimate responsibility for ensuring that your actions—and the actions of those under your direction—comply with the antitrust laws.
Antitrust Guidelines
You must avoid any discussions or conduct that might violate the antitrust laws or even raise an appearance of impropriety. The following guidelines will help you do that:
- Do not, without prior review by your company’s legal counsel, have discussions with other attendee companies that may touch on sensitive antitrust subjects, including but not limited to:
- Your company’s prices or pricing methodology for products, assets or services, or prices charged or pricing methodologies used by your competitors;
- Costs, discounts, terms of sale, profit margins or anything else that might affect those prices;
- Allocating markets, customers, territories, products or assets with your competitors;
- Limits on sales volumes of certain products or services;
- Strategic plans, including non-public business expansion or contraction plans;
- Employee salaries and wages, or limitations on hiring a competitor’s employees; or
- Any competitively sensitive information concerning your own company or a competitor’s.
- Do not stay at a meeting, or any other gathering, if those kinds of discussions are taking place.
- Do consult your company’s legal counsel about any discussions and/or documents that touch on sensitive antitrust subjects such as pricing, market allocations, refusals to deal with any company, and the like.