AntiTrust Policy

Position

The Federation has a zero-tolerance policy in respect of anti-competitive behaviour. Such behaviour is as described in the Commerce Act 1986 and the Fair Trading Act 1986 and successive amendments or legislation.

Process to Mitigate Risk

Notification

At all meetings, seminars, training courses or conferences of the Federation, the following statement shall be read prior to the commencement of any business. The Statement shall also be reproduced in training course material produced by CBAFF and appear on the Federation’s website.

Members are reminded that there must be no discussion of prices, surcharges, fees, costs, particular customers, revenues, market shares, or any other commercially sensitive topics .In particular you are reminded that no market agreements have been or will be decided at meetings of CBAFF whether they involve prices, amount or areas.

Such behaviour also outside of meetings is prohibited; otherwise you could cause immense damage to CBAFF and/or your company.

Should it be apparent that at a meeting, seminar, training course, conference or other function there is an attempt to make or discuss an open or hidden agreement regarding price, amount or area, CBAFF management will be obligated to intervene and if necessary to break off the meeting.

Should doubt exist whether an activity of the Federation to be decided on is admissible according to anti-trust law, the Federation’s management shall clarify the allowability of the activity.

Members should also be reminded of their obligations at meetings that are not hosted by CBAFF.

Records

Minutes of meetings shall be kept recording decisions taken. A copy of presentations made to seminars and conferences shall be retained and notes taken of any discussion held, which shall be accepted as a valid record of proceedings.

Action

In the event that discussions appear to begin discussing matters that are prohibited, the Federation’s most senior officer present shall remind those concerned, of the Federation’s policy and advise that the meeting/event will be suspended if the discussion does not cease immediately.

In the event that other circumstances occur that appear to be in breach of this policy, the Federation shall take action to ensure that its zero tolerance policy is maintained. The matter will be investigated and appropriate action will be taken which may include termination of membership and referral to the appropriate Government organisation.

November 2012