WIMAR Competition Compliance Policy and Statement

1.     Competition Compliance Policy

WIMAR Members will comply with relevant competition laws and regulations in respect of all WIMAR Activities. Members acknowledge that they may be competitors and cannot discuss or exchange confidential or competitively sensitive information (CSI).

CSI includes non-historical (over 12 months old), non-public information including in relation to pricing (including pricing components), profit margins, costs, sales and production volumes, stock levels (including warehousing), employee salaries, capital investment and business strategy documents.

This Competition Policy is intended to supplement, and not to replace, any other compliance obligations to which an individual member is also subject, for example by virtue of his/her employment with a WIMAR [corporate] member.

2.     Meetings

Meetings of the board, and any sub-committees, of WIMAR will have an agenda that will be circulated in advance for review. No off-agenda items will be discussed. Minutes of such meetings will be prepared and also circulated to relevant members for review.

Each meeting of the board, and any sub-committees, and any Industry Seminar or similar event will start with a reminder to all members of the importance of complying with competition law.

3.     Competition Compliance Statement

“As you know, it is WIMAR’s policy to comply fully with all applicable laws, including competition laws. This meeting will be conducted in accordance with this policy.

You are reminded that you should at all times (before, during and after this meeting) refrain from discussing any information which is confidential to your company and/or which is likely to affect your commercial strategy (for example, disclosure of prices, costs, production plans).

Infringement of competition law may bring with it serious consequences for you as an individual, the companies you represent and WIMAR itself.

If any discussion might be construed as being sensitive from a competition law perspective, we will bring an end to that topic of discussion. You should likewise not hesitate to voice any concerns you may have.”