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ANTITRUST GUIDELINES FOR MEETING PARTICIPANTS

V2023-09-18

SUMMARY 

Participants must be aware that competition law necessitates great care when
having any contact with competitors, including in industry forums such as the
meeting which is referencing this document. As participants of this group may
compete with each other in various aspects of their businesses, they are asked
to:  

 1. remind themselves of the competition compliance training they should have
    received from the organisation they represent; and  
 2. not discuss any competitively sensitive information at any meeting or
    associated gatherings/discussions.  

Please note that this guidance is not intended to be or contain legal advice.
Each participating organisation is advised to seek its own appropriate legal
advice with respect to compliance with applicable antitrust laws, including its
own internal policies. 

PROCEDURE FOR ALL MEETINGS  

 1.  At the beginning of each meeting, the participants should be reminded of
    this document and to note any of their obligations under competition law.  
 2. An agenda must be circulated in advance of each meeting. It should include a
    complete list of topics for discussion and should not include an “any other
    business” item or equivalent.  
 3. Participants should ensure that they are comfortable with the proposed
    agenda, if necessary taking advice from their respective organisation’s
    legal teams.  
 4. All meetings must proceed strictly in accordance with the agenda circulated
    in advance of the meeting by its organiser, and will be recorded in
    minutes. 
 5. Participants must review the minutes to ensure that they reflect the actual
    discussions held at the meetings.  
 6. The participants should be sensitive at all times to ensure that remarks
    made in meetings or associated gatherings cannot be misinterpreted.  
 7. If any discussions that may be contrary to competition law are initiated,
    the Chair of the meeting should immediately bring such discussions to a
    close.  
 8. Discussions at gatherings should not involve any disclosure/discussion of
    confidential information, including in particular (although this list is not
    exhaustive):
    1. no disclosure or discussion of the participants’ fee schedules, pricing
       policies, current or future margins, or identification of customers;  
    2. no disclosure or discussion of any participants’ future plans (such as
       new products or changes to existing services, prospective clients,
       business opportunities or product development plans), strategic /
       expansion plans;  
    3. no disclosure or discussion of prices, commissions paid or payable to, or
       any other terms and conditions of arrangements between the participants
       and their suppliers, partners or other intermediaries.  






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