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| Competition law compliance guidelines on participation at PRIMA meetings and activities |
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Competition law compliance guidelines on participation at PRIMA meetings and activities
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PRIMA´s objective is to bring together suppliers and others involved in the European paper industry to discuss issues of industry-wide importance and to stimulate a better knowledge on the industry and the various sectors along the paper chain. PRIMA is not intended to become involved and will not become involved in business decisions of its members and member companies nor is it intended in any respect to restrict competition between actors in the paper industry or in any other sector nor will it facilitate any anti-competitive behavior. It is the policy of PRIMA to strictly comply with all laws and regulations applicable to its activities, including EC and national competition rules. It is the responsibility of every individual PRIMA member and participant to PRIMA events to strictly comply with the competition rules during all PRIMA activities. The PRIMA Council, through these guidelines, want to express the association´s strong commitment to competition policy and to competition law.
Penalties that may be imposed for infringements of competition law are severe and can take the form of fines, civil liability for damages and, in some countries, criminal sanctions.
The purpose of the present guidelines is to assure that all PRIMA members (including their employees or representatives) and other participants to PRIMA activities are aware of the existence of EC competition law rules. These guidelines also are intended to help avoid activities or bePRIMA´s objective is to bring together suppliers and others involved in the European paper havior that violate competition law rules. Naturally, these guidelines are not comprehensive and can not be considered as a substitute for competent legal advice.
In order to avoid infringing competition rules all PRIMA members and any other participants during PRIMA activities and events should refrain from:
- Any discussion or arrangement with competitors (directly or indirectly) on sensitive topics, such as for instance, their own or their competitor´s prices (or any element that directly or indirectly could affect price or pricing decisions such as e.g. discount policy, profit margins, costs, payment terms and other terms and conditions of sale), business plans, customer relations, sales strategies, investments, capacity, output, etc.
- Any arrangement on dividing up customers, sales territories or products;
- Any other arrangement restricting competition, such as for instance, a collective boycott, any arrangement to avoid direct competition or joint action to exclude competitors or new entrants to the market;
- Any participation in information exchanges or market surveys that allow access to and identification of individualized competitive or sensitive business information;
To be prohibited by competition law, an agreement or arrangement need not be written down or be binding. An informal arrangement or even a "gentlemen´s agreement" can constitute an infringement.
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