ANTITRUST COMPLIANCE STATEMENT
Steel Plus Network, LLC, is an international association (“SPN”), organized to serve its structural steel fabricator and supplier members. Its purpose is to provide, through its activities, events, and meetings, common ground where fabricators and suppliers can become informed of current developments in the steel fabrication industry and otherwise advance that industry’s contribution.
SPN is not intended to, and may not, play any role in competitive decisions of its members or suppliers, nor in any way restrict competition among participants in the steel fabrication industry.
It shall be the responsibility of every member of SPN to be guided by SPN’s policy of strict compliance with the antitrust laws in all SPN activities, events, and meetings. It shall be the special responsibility of SPN officers and staff to assure that this policy is known and adhered to in the course of activities pursued under their leadership.
To assist SPN staff and all of its officers in recognizing situations which may raise the appearance of an antitrust problem, the Board of Managers will, as a matter of policy, furnish to each such person this Antitrust Policy Statement. Should questions arise as to the manner in which the antitrust laws may apply to the activities of SPN, such questions shall be directed to SPN’s headquarters and/or its counsel, as appropriate.
Antitrust compliance is the responsibility of every SPN member. Any knowing violation of the SPN general rules of antitrust compliance or with this general policy by an SPN member will result in that person’s immediate suspension from the membership in SPN, and immediate removal from any office held.
General Rules of Antitrust Compliance
The following rules are applicable to all SPN activities and must be observed in all situations and under all circumstances without exception or qualification:
- Neither Steel Plus Network, LLC, nor any activity or event held by SPN, shall be used for the purpose of bringing about or attempting to bring about any understanding or agreement, written or oral, formal or informal, express or implied, among competitors with regard to prices, terms or conditions of sale, distribution, volume of production, territories or customers.
- No SPN activity, event, or communication shall include discussion for any purpose or in any fashion of pricing methods, production quotas, or other limitations on the timing, costs, volume, production, terms of sale, or allocation of territories or customers.
- No SPN activity, event, or communication shall include any discussion which might be construed as an attempt to prevent any person or business entity from gaining access to any market or customer for goods or services, or to prevent any business entity from obtaining a supply of goods, or otherwise purchasing goods or services freely in the market.
- No SPN activity, event, or communication shall include any discussion which might be construed as an agreement or an understanding to refrain from purchasing any raw materials, equipment, services or other supplies from any supplier.
- In conducting meetings, the Chair and the President shall prepare and follow a formal agenda. Minutes of the meeting shall be distributed to all members. Approval of the minutes shall be obtained from the Board or Executive Committee at its next meeting.
- Speakers at SPN meetings or events shall be informed of the need to comply with SPN’s antitrust policy in their presentation.
- In informal discussions at the site of an SPN meeting, event, or activity, but beyond the control of its President, all members are expected to observe the same standards of personal conduct as are required of the SPN in its compliance with these antitrust guidelines.