ALUMINUM ANODIZERS COUNCIL

 Antitrust Policy

The Aluminum Anodizers Council is committed to strict compliance with all laws applicable to carrying out its objectives, and in the conduct of its activities. Its programs involve cooperative efforts to accomplish those objectives, including the frequent meeting of competitors and their suppliers. It is therefore important to emphasize the ongoing responsibility of the Council and its members to comply fully with federal and state antitrust laws.

The officers and directors, as governing representatives of the membership, are aware of their responsibility and conduct their meetings and adopt programs and activities in strict compliance with all laws applicable to associations. An equal responsibility for antitrust compliance rests with all members of the Council. Your corporate employer and the Council depend on you as a member to use your good judgment to avoid all discussions and activities which may involve improper subject matter, or discussions which may have unintended implications, and avoidance of even an appearance of improper activity. You, who are directly involved in the industry either as a manufacturer or supplier, must take every precaution to assure that your conduct at association meetings or with competitors at any time will not have implications of an antitrust nature. The following guidelines are for your guidance in your relationships with your fellow members.

Guidelines

1. DON'T discuss with other members your own or competitors' prices, pricing procedures, or anything that might affect prices such as costs, discounts, terms of sale, or profit margins, or anticipated wage rates.
2. DON'T stay at a meeting where any such price talk occurs.
3. DON'T make public announcements or statements about your own prices or those of competitors at any Council function.
4. DON'T talk about what individual companies plan to do in particular geographic or product markets or with particular customers.
5. DON'T disclose to others at meetings or otherwise any competitively sensitive information.
6. DO have a Council staff person present at any meetings you conduct and insist on the agenda being followed and minutes kept.
7. DO confer with legal counsel before bringing up any topic or making any statement with competitive ramifications.
8. DO send copies of all association-related correspondence to the Council office.
9. DO alert the Council staff to any inaccuracies in proposed statements to be made by the association on behalf of the industry, particularly statements to government officials.
10. DO remember that meetings with government officials may not provide a shield against antitrust liability.

Conclusion

Compliance with these guidelines involves not only avoidance of antitrust violations, but avoidance of any behavior which might be so construed. Bear in mind, however, that the antitrust laws are stated in general terms, and that this statement is not a summary of applicable laws. You must, therefore, seek the guidance of your own corporate counsel if antitrust questions arise.