Antitrust Compliance: Quick Reference

NAPO has in effect an Antitrust Compliance Policy (“Policy”). It is intended for the guidance of NAPO’s member company representatives, officers, directors and staff, when engaged in any activity conducted in the name of, or on behalf of, NAPO. All such persons are expected to be familiar with the Policy and to follow it both in letter and spirit.

The following cautionary statements are taken from the full Policy and are intended to be used as a quick reference tool. This document is not a substitute for the full Policy, which is available from the Association’s office and with which all are expected to be conversant.

The following topics should be scrupulously avoided in all cases:

• Current or future prices, price levels, costs or margins.
• What is a fair or rational profit level.
• Actions which could lead to standardizing or stabilizing prices.
• Pricing or bidding methodologies or procedures, including the timing of implementation of price changes and whether or how prices are advertised.
• Price discounts, rebates, service charges or other terms and conditions of sale.
• Credit terms.
• Product warranty terms.
• Actual, planned or projected production, production capacity, capacity utilization or demand, including confidential company plans for new products.
• Allocating geographic or product markets or customers.
• Whether to do business with a supplier, competitor or customer.

At NAPO gatherings, all NAPO members, their representatives and guests should avoid discussion of competitively sensitive subjects. Please be advised that the Policy applies not only while the meeting is in session, but also during breaks and particularly during receptions, meals and other social events surrounding the meeting. Suggested wording to start NAPO meetings and gathers is provided below.

This meeting, as are all NAPO board, committee, SIG, and chapter meetings, will be conducted consistently with NAPO’s Antitrust Compliance Policy.  The full policy and one-page summary of the policy is found in POINT’s Member Connect Community Library and on www.napo.net/page/antitrust. Please be advised that the Policy applies not only while the meeting is in session, but also during breaks and particularly during receptions, meals and other social events surrounding the meeting.  If you have not read the Policy summary, please do so. If you have any questions, please contact a member of the Board or HQ Team.

We hope the above rules will be helpful as you participate in NAPO meetings and other activities. If you have any questions about antitrust compliance, do not hesitate to contact NAPO Headquarters.