Antitrust & Harassment Compliance Guidelines

Introduction

MEA and our member companies are committed to full compliance with all laws and regulations, and to maintaining the highest ethical standards in the way we conduct our operations and activities. Our commitment includes strict compliance with both federal and state antitrust and harassment laws, which are designed to protect this country’s competitive economy and provide a safe and respectful work environment.

Responsibility for Compliance

Compliance with the antitrust and harassment laws is a serious business. Violations may result in heavy fines for corporations, and in fines and even criminal sanction for individuals. Each member and staff employee bears the ultimate responsibility for assuring that their actions and the actions of any of those under their direction comply with these laws.

General Guidelines

Antitrust
In all MEA operations and activities you must avoid any discussions or conduct that might violate the antitrust laws or even raise an appearance of impropriety. The following guidelines will help you do this:

• Do consult counsel about any documents that touch on sensitive antitrust subjects such as pricing, market allocations, refusals to deal with any company, and the like.
• Do not have discussions with other member companies about:
  • Your company’s prices for products or services, or prices charged by your competitors
  • Costs, discounts, terms of sale, profit margins, or anything else that might affect those prices
  • The resale prices your customers should charge for products you sell
  • Allocating markets, customers, territories, or products with your competitors
  • Limiting production
  • Whether or not to deal with any other company
  • Any competitively sensitive information concerning your own company or a competitor’s
• Do not stay at a meeting, or any other gathering including web forums, if those kinds of discussions are taking place.
• Do not discuss any sensitive antitrust subjects (such as price discrimination, reciprocal dealing, or exclusive dealing agreements) without first consulting counsel.
• Do not create any documents or other records that might be misinterpreted to suggest that MEA condones or is involved in anticompetitive behavior.

Harassment
It is our policy to provide an environment free from sexual harassment. No member or staff employee should be subjected to unsolicited or unwelcome sexual overtures or conduct, either written, physical, or verbal. This also means not engaging in conduct of a sexual nature—either physical or verbal—which is unwelcome, intimidating, or hostile.