Anti-Trust Compliance

It is the policy of PUG to conduct all activities (including those of its committees, subcommittees, work groups and task forces, if any) in strict compliance with all applicable antitrust and competition laws. PUG expects all participants in its activities, including invited guests, to also comply.

Items of particular importance and concern center around the following activities:

  • PUG and its members should not, in substance or in appearance, engage in any activity that could be considered to restrain trade or act as a barrier to commerce to any individual or group of individuals.
  • Committees, subcommittees, work groups and task forces, if any, should have and maintain written terms of reference regarding their composition, organization and scope of work (and all activities should remain within the scope of work).
  • Meetings and telephone conferences (including those of its committees, subcommittees and task forces, if any) should have proper notification, prior written agenda, antitrust reminder at the start and minutes.  Adherence to the specific items on the agenda will support compliance with PUG antitrust policy and avoid any appearance of impropriety.
  • Members [and PUG personnel, if any] must take special care to avoid making statements or engaging in conduct which would, in substance or in appearance, be prohibited by PUG antitrust policy. Should members have any doubt concerning the propriety of any matters under discussion at any meeting of PUG, they should promptly raise their concern and the discussion should cease on the affected subject until legal advice is obtained allowing continuation.
%d bloggers like this: