1. Purpose

This policy ensures that all activities of [Company/Association] and its employees comply fully with Swiss competition law (Cartel Act, SR 251) and EU competition law (Articles 101 and 102 TFEU, and related regulations). The objective is to prevent anti-competitive practices, safeguard fair competition, and protect [Company/Association] and its staff from legal, financial, and reputational risks.

2.⁠ ⁠General Principles
We compete fairly and independently in all markets.
We do not engage in agreements or coordinated practices that restrict competition.
We respect the independence of our competitors, customers, and partners.
All employees must immediately report potential risks of non-compliance.

3.⁠ ⁠Prohibited Conduct
Employees, officers, and representatives shall not engage in:
a) Agreements with Competitors
-Fixing or coordinating prices, fees, discounts, or trading conditions.
-Limiting or controlling production, markets, or technical development.
-Allocating customers, suppliers, territories, or market shares.
-Boycotts or collective refusals to deal.
b) Abuse of Market Power
-Exploitative conduct such as imposing unfair prices or conditions.
-Exclusionary conduct such as denying access to essential infrastructure, tying/bundling, or predatory pricing.
c) Information Exchange
-Sharing sensitive, non-public information (prices, costs, margins, production capacity, tenders, R&D, strategic plans).
-Using industry meetings to coordinate behaviour.
4.⁠ ⁠Permissible Conduct
-Participation in standards development, technical cooperation, or joint R&D projects when conducted under transparent, non-discriminatory rules and in line with EU/Swiss competition exemptions.
-Exchanging public, historical, or aggregated market data that does not reduce competition.
-Collaboration with authorities where legally required (e.g., reporting obligations, compliance with regulations).

5.⁠ ⁠Industry Associations & Meetings
When attending trade associations, working groups, or standards bodies:
-Meetings must have a clear agenda and minutes.
-Avoid discussions on prices, costs, capacity, markets, or any commercially sensitive information.
-Leave the meeting immediately if such discussions occur, and report the incident.

6.⁠ ⁠Compliance Responsibilities
-All employees and managers must undergo regular antitrust compliance training.
-The Compliance Officer/Legal Department must be consulted in case of doubt.
-Violations will result in disciplinary action and possible reporting to authorities.

7.⁠ ⁠Enforcement
Failure to comply may lead to severe consequences under Swiss and EU law, including fines of up to 10% of global turnover, personal liability, and reputational damage.