We believe in putting good products and services into the marketplace and letting free, fair, and open competition drive our success or failure. We succeed based on our own merits and avoid any conduct that could restrict free trade.
Antitrust and competition laws promote fair competition, and we comply fully with all such laws. Violations of antitrust or competition laws may result in severe legal penalties for our company and criminal charges for the individuals involved.
You have a responsibility to understand local antitrust and competition laws and, where necessary, consult the CoorsTek Legal Department for guidance.
You may from time to time have conversations with competitors, such as at a trade show or trade association meeting. You must exercise caution when interacting with competitors and follow these rules:
- Do not discuss prices, pricing policies, costs, marketing or strategic plans, technology improvements, or proprietary or confidential information
- Do not make any agreement or understanding to:
- Raise, set or hold (“fix”) prices on products or services
- Divide territories, customers or markets
- Prevent another company from entering the market
- Refuse to deal with a customer or supplier
- Interfere with a competitive bid process (“bid rigging”)
- Restrict production, sales or output
In the normal course of business, we acquire information about our competitors, but we do so honestly and lawfully. We recognize that using dishonest, illicit, or illegal methods to acquire another company’s trade secrets or other confidential information is wrong.
With respect to information about our competitors, you are expected to:
- Always respect the confidential information and intellectual property rights of our competitors
- Only seek to gather competitive information from publicly available sources, such as media reports, trade journals, annual reports, government filings, public speeches of company executives, and customers when freely provided to meet a competitive offer
- Never gather competitive information through dishonest, illicit or illegal activity, such as theft, trespassing, eavesdropping, computer hacking, misrepresentation, or hiring a competitor’s employee just to obtain the competitor’s confidential information
TRUTH IN SALES AND MARKETING
Another part of acting honestly and lawfully in our marketplace is giving customers only accurate and truthful information about the quality, features, and availability or our products and our competitors’ products.
When speaking with customers, you should never:
- Use misleading statements in our marketing
- Make claims about our products or services that have not been substantiated
- Make disparaging remarks about our competitors