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SECTION 12 SEKO absolutely prohibits any consultation with

competitors relating to prices or terms and
ANTITRUST conditions of sale.

For purposes of clarity, some examples of conduct that
SEKO conducts its business ethically and in may be construed as unlawful and contrary to Antitrust
compliance with all laws in the countries where laws include, but are not limited to:
SEKO does business - including all state, federal
and international antitrust laws such as the U.S. (a) price-fixing with the competition;
Sherman Act, U.S. Clayton Act, U.S. Federal Trade
Commission, as amended, and EU Antitrust Laws. (b) rigging bids with the competition;
SEKO Representatives MAY NOT directly or indirectly
communicate with the “competition” and display (c) conspiring with the competition;
any form of unlawful restraints, price-fixing, price
discrimination, exclusive dealing arrangements, (d) destruction of documents in an effort to achieve
conspiracy, monopolies, prices, profit margins, or hide any of the foregoing motives; and
and/or discounts in any engagements. Compliance
with the law requires obedience both to the letter (e) price discrimination.
and spirit of the law.
ANY INFRACTION OF SEKO’S ANTITRUST
A basic tenet of SEKO policy is that no employee
shall enter into any understanding, agreement, plan POLICY OR THE ANTITRUST LAWS WILL
or scheme, whether express or implied, formal or SUBJECT ANY EMPLOYEE TO LEGAL
informal, oral or written, with any competitor with PENALTIES AS WELL AS CORPORATE
respect to prices, terms or conditions of sale, output, DISCIPLINE, UP TO AND INCLUDING
production, distribution, territories or customers. DISMISSAL FROM EMPLOYMENT.

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