EMVEnergy Solutions, LLC (EMV Energy, EMVENERGY) is committed to strict compliance with all Federal and state laws and regulations, and to the highest ethical standards in the way we conduct our operations. This includes strict compliance with federal and state antitrust laws, to protect and enhance our country’s free, competitive economy.
You are Responsible for your Antitrust Compliance.
Compliance with the antitrust laws is a serious business. Antitrust violations may result in heavy fines for corporations, and in fines and imprisonment for individuals. While EMV Energy may provide guidance on antitrust matters, you bear the ultimate responsibility for assuring that your actions comply with the antitrust laws.
EMV Energy’s Antitrust Guidelines For Meetings
You must avoid any discussions or conduct that might violate or even appear to violate the antitrust laws. The following guidelines will help you do that:
Do consult with antitrust counsel about any documents or data that could raise antitrust issues, such as information about prices, production, or any proposed action that may disadvantage customers or competitors.
Do consult with antitrust counsel on any non-routine correspondence that requests an EMV Energy consultant member or client company to participate in projects or programs with others, collect data for such activities, or otherwise join other member companies in EMV Energy actions.
Do follow an approved agenda. Have counsel review the agenda and minutes of the meeting before they are put into final form and circulated.
Do not communicate – either directly or indirectly -- with other companies In the sector, whether members partners, clients or not, about:
Any company’s (including your own) prices for products or services;
Discounts, credit terms, other terms of sale, profit margins or anything else that might affect prices;
Allocating markets, customers, territories or products with your competitors;
Bids for, or solicitations of, particular customers or business;
Any company’s (including your own) inventory, capacity, or production;
Whether or not, or how, to deal with any other company;
Any marketing or production plans or other competitively sensitive information concerning your own company or a competitor.
Do not stay at a meeting, or any other gathering, if those kinds of discussions are taking place and do note your objection to the discussion.
Do not take notes or create any documents or other records that might be misinterpreted to suggest that EMV Energy condones or is involved in anticompetitive behavior.
Whenever you have any question about whether particular EMV Energy activities might raise antitrust problems, please contact us immediately.
EMV Energy 2018
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