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Various LTS product offerings contain a peer activity component where clients with similar job roles within an organization, in the same or different industries, are convened by LTS to exchange knowledge, impart insights and share best practices related to their issues and challenges. These offerings include, but are not limited to, the Retreats and Let’s Talk Security Forums. In connection with these peer activities LTS often serves as moderator to facilitate discussion on topics that participants deem relevant. Participants in LTS peer activities must be sensitive to discussion topics that might implicate antitrust/competition laws. To ensure that the participants understand and comply with these laws, LTS is providing you with these Antitrust Guidelines, which constitute basic rules for interacting that are designed to avoid antitrust issues. We encourage you to review the Guidelines carefully and consult your own legal counsel if you have any questions. The Antitrust Guidelines, which are applicable globally, are incorporated into the meeting and/or online registration materials for all LTS peer activity offerings. Along with the Antitrust Compliance Policy Statement attached as Exhibit I, the Antitrust Guidelines are intended to remind participants of their obligations in connection with their involvement in LTS peer activities. Antitrust compliance is the responsibility of every peer activity participant; as such we ask that you keep these Guidelines in mind when interacting with other participants at any LTS peer activity. LTS assumes no responsibility for ensuring that peer activity discussions are appropriate and not in violation of any antitrust/competition laws. If you as a participant have any questions in this regard, you must consult your own legal counsel.
Agreements, whether written or verbal, or those that may signal or otherwise constitute tacit understandings that have the effect of lessening competition, could violate antitrust laws and expose participants of the LTS peer activities to substantial legal liability.
| Do: | For Example: |
| Adhere to the meeting agenda and/or activity program. | Various gatherings, including the Retreats and Let’s Talk Security Forums, have prepared agendas that are circulated in advance to all participants. |
| Follow the Discussion Guidelines below | |
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| Do Not: | |
| Engage in discussions regarding prices, fees or rates. | For example:
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| Engage in discussions related to production capacity. | For example:
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| Make any statements that could be interpreted as an invitation to coordinate behavior. | Do not say:
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| Make any agreements allocating customers or geographic territories or markets. | Do not agree to refrain from competing for certain customers or in certain countries in exchange for not having to face competition from another customer or in another country. |
| Disclose any disaggregated, customer-specific information. | For example:
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| Discuss future plans regarding product lines. | Do not disclose new product lines or research and development expenditures. |
| For example:
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| Discuss your company’s commercial strategy (which may be interpreted as an invitation to coordinate strategies or to otherwise enable a coordination of strategies) or agree on a joint strategy relating to the operation of your business. | Do not discuss or agree:
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| Agree on uniform terms and conditions on which to deal with certain customers or suppliers that you have in common. | If your company and another company both sell products or services to the same customer, do not
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| Agree to forego entering into new lines of business that compete against the company of the participant with whom you are talking. | If your company is intending to enter a new business, do not discuss with another company in that same business or industry the terms upon which you should or should not compete in that market. |
Note: “Potential” competitors are subject to the same rules as “actual” competitors, and should take care to follow all of the Guidelines that are discussed above.
Exhibit I
Peer activities/antitrust compliance Policy Statement
As described in the Peer Activities Antitrust Guidelines, it is the obligation of all participants in any LTS peer activity to comply at all times with all applicable antitrust laws, and to refrain from engaging in anticompetitive conduct. This includes, but is not limited to, the following:
LTS assumes no responsibility for ensuring that discussions conducted during peer activities are appropriate and are not in violation of any antitrust laws. Participants who have any questions in this regard must consult their own legal counsel.
