Competition Compliance Policy
The following outlines Ekco’s Competition Compliance Policy.
• It is our policy to conduct all our business in an honest, integrity and in an ethical manner;
• Ekco complies with all applicable antitrust laws;
• Under no circumstances will Ekco directly or indirectly be involved in conduct that leads restraint on
trade or otherwise violates antitrust laws;
• Any conduct by Ekco directors or employees that is contrary to antitrust law is contrary to Ekco policy;
• Any director or employee found in violation of this policy or applicable antitrust laws will be subject to appropriate disciplinary action.
This policy should be read together with the Employee Handbook and other relevant policies and guidelines.
Scope
This Policy sets out the minimum standards enshrined in Ekco’s competition compliance culture. Ekco welcomes the development of free market economies and competition, which ultimately benefits our customers, suppliers, and Ekco ourselves.
Every Ekco manager and employee is expected to take full responsibility for antitrust compliance and always ensure correct individual behaviour.
Definitions
Antitrust laws protect free and unrestricted competition between all players at all levels of the supply chain.
In summary, antitrust laws prohibit:
• agreements or concerted practices (such as a common understanding) that aim at or result in the restriction of competition;
• the abuse of a dominant position.
This means that Ekco must compete independently from other market players and must not seek to control the commercial policy and practices of its competitors, suppliers, or customers.
Ekco must not coordinate its competitive behaviour with other companies to try to avoid or reduce the rigours and uncertainty of a competitive marketplace.
| Term | Definition |
|---|---|
| Price fixing | Price fixing between competitors is one of the most serious breaches of antitrust laws and is regarded as a hard-core cartel, punishable by the highest levels of fines; it is also a criminal offence punishable with imprisonment in many countries. Price fixing relates to any agreement or concerted practice between competitors that restricts or aims to restrict price competition. |
| Market sharing | Agreements and concerted practices between competitors to allocate markets, whether by product, territory, channel, type, or size of customer, or in any other way, are illegal. |
| Bid rigging | Co-ordinating tenders between competitors is a serious infringement of antitrust law and a criminal offence in many jurisdictions. Competitors must bid independently of others. |
| Exchange of commercially sensitive information |
It is not permissible to exchange confidential information which may reduce or remove any degree of uncertainty between competitors in respect of current or future market conduct. The mere receipt of such information can be illegal, even if the employee does not reciprocate by disclosing similar information. |
Raising Concerns
If you have any questions about this policy or any concerns regarding the contents of this policy, please discuss with your line manager or raise the issue with the People Operations Team.
Exceptions
There are no exceptions to this policy statement.
Last Updated: December 2023
