SECTION 12 ANTITRUST
SEKO absolutely prohibits any consultation with competitors relating to prices or terms and conditions of sale. For purposes of clarity, some examples of conduct that may be construed as unlawful and contrary to Antitrust laws include, but are not limited to:
SEKO conducts its business ethically and in compliance with all laws in the countries where SEKO does business - including all state, federal and international antitrust laws such as the U.S. Sherman Act, U.S. Clayton Act, U.S. Federal Trade Commission, as amended, and EU Antitrust Laws. SEKO Representatives MAY NOT directly or indirectly communicate with the “competition” and display any form of unlawful restraints, price-fixing, price discrimination, exclusive dealing arrangements, conspiracy, monopolies, prices, profit margins, and/or discounts in any engagements. Compliance with the law requires obedience both to the letter and spirit of the law. A basic tenet of SEKO policy is that no employee shall enter into any understanding, agreement, plan or scheme, whether express or implied, formal or informal, oral or written, with any competitor with respect to prices, terms or conditions of sale, output, production, distribution, territories or customers.
(a) price-fixing with the competition;
(b) rigging bids with the competition;
(c) conspiring with the competition;
(d) destruction of documents in an effort to achieve or hide any of the foregoing motives; and
(e) price discrimination.
ANY INFRACTION OF SEKO’S ANTITRUST POLICY OR THE ANTITRUST LAWS WILL SUBJECT ANY EMPLOYEE TO LEGAL PENALTIES AS WELL AS CORPORATE DISCIPLINE, UP TO AND INCLUDING DISMISSAL FROM EMPLOYMENT.
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