ANTITRUST LAW COMPLIANCE POLICY STATEMENT

Effective Date: December 31, 2021

ANTITRUST LAW COMPLIANCE POLICY STATEMENT

Federal antitrust laws are aimed at promoting free and open market competition, and punishing individuals and corporations that unreasonably restrict competition.

The Center for Workplace Compliance (CWC) is committed to following the letter and spirit of all applicable antitrust laws. It is not organized to, and may not, play any role in the competitive decisions of its members or their employees, nor may it in any way restrict competition among members or potential members. Rather, CWC provides a forum for exchange of ideas in a variety of settings including its membership meetings and conferences, educational programs, and Board meetings.

CWC's Board of Directors recognizes the possibility that the Association and its activities could be viewed by some as an opportunity for anti-competitive conduct. The aim of this policy statement is to communicate the Association's uncompromising policy to comply strictly in all respects with antitrust law and principles.

Violations of antitrust laws can result in serious consequences, including stiff fines for the Association and its offending leaders, jail sentences for individuals who participated in the violation, and even court-imposed dissolution. An executive who merely attends a meeting at which competitors engage in illegal discussions may be held criminally responsible, even if he or she says nothing at the meeting. The executive's attendance at the meeting may be sufficient to imply acquiescence in the discussion, making him or her liable to as great a penalty as those who actively participated in the illegal agreement.

Some activities by competitors do not implicate antitrust laws. Other activities, however, are so harmful that they are considered automatic violations, whether or not the activities actually have a harmful effect on competition. These generally include price fixing and some forms of boycotts. For that reason, there are some subjects that CWC Officers and Directors should avoid discussing entirely when they are together — both at formal gatherings and in informal settings.

To avoid even the appearance of impropriety, it is the Board's policy to avoid any discussion of prices, pricing policies, terms or conditions of doing business, or any other discussion that could be perceived as coercive or exclusionary towards another company. Under no circumstances may CWC Board meetings or activities be used as a means for competing companies to reach any understanding, expressed or implied, that is intended to, or may, restrict competition or impair the ability of members to exercise independent business judgment regarding matters affecting competition.


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