Integrity Standard - Fair Competition
Policy:
The Company is committed to a policy of vigorous, lawful,
and ethical competition which is based on the merits of
our products and services. We will maintain the trust of
our customers and providers by developing and providing
high-quality products and services in a fair, ethical, and
legal manner.
We will maintain our customer’s trust by striving
to ensure that our sales materials, advertisements, and
other communications accurately and fairly describe our
products and services.
We will promote our products and services through fair
and accurate comparisons with our competitors.
It is the policy of the Company to comply with all applicable
antitrust and competition laws. These laws are very complex,
but, in general, they prohibit agreements or conduct that
may restrain trade or reduce competition. They are intended
to provide a variety of products and services at competitive
prices.
We will avoid all contracts, agreements,
and understandings which unlawfully reduce or eliminate
competition or the production or sale of products or services.
We will refuse any agreements with competitors
to establish or fix prices or to divide or allocate markets
either by market segment, geography, or by any other means.
We will exercise special care to ensure
that our discussions and activities with representatives
of other companies are in compliance with antitrust laws.
Employees who have questions about potential
antitrust implications or antitrust practices should contact
the Legal Department.
We will compete fairly. Information about competitors,
customers, and providers is a valuable asset in a highly
competitive market. However, no illegal or unethical means
of obtaining this information will be tolerated. No information
should be sought or used that would violate antitrust laws
or laws and contracts protecting proprietary data.
Questions & Answers
Q. A representative of one of our
competitors proposes that we both freeze our prices
for one of our products for a six-month period to show our
mutual commitment to restraining health care costs. The
other company’s representative says this is legal
because we are limiting the price we will charge consumers.
Is it legal?
A. No. It may be illegal. Maximum price
fixing agreements may be just as illegal under the antitrust
laws as minimum price fixing agreements. You should avoid
any discussion of prices with competitors and consult with
the Legal Department anytime you receive a similar proposal.
Q. Do I have to have to give a specific reason for
refusing to do business with a particular producer, vendor,
or consultant?
A. We have broad discretion to decide with
whom we will do business as long as we have legitimate business
reasons and are not engaged in anti-competitive practices.
If you have any questions about whether a particular practice
is anti-competitive, contact the Legal Department.
Remember, if you do not understand, or if you have
any questions concerning, this Integrity Standard or any
other part of the Code, contact your Supervisor, a higher
level Supervisor, any of the Corporate Resources or call
the Corporate Integrity HOTLINE
(1 800 838-2552).
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