Danfoss Drives Club Carremm Controls Instructions

Danfoss Drives Club Carremm Controls

INSTRUCTION MANUAL

The Competition Guidelines Manual provides rules and guidance on avoiding competition issues to ensure compliance with competition laws globally.

A SIMPLE GUIDE TO AVOIDING COMPETITION ISSUES

The following rules are not a comprehensive list, but instead are intended to serve as a guide.

THE COMPETITION RULES:

Competition laws around the globe generally prohibit any agreement or concerted practice between competitors that has the object or effect of preventing, restricting or distorting competition.

Be careful: “Agreement” covers a lot of arrangements:

• informal or formal;
• legally binding or not;
• written or oral;
• explicit or tacit.

A “gentleman’s agreement” or a simple “understanding” is enough!

DO…

• Compete vigorously and independently.

DO NOT…

• DISCUSS OR REACH AGREEMENTS WITH COMPETITORS ABOUT: terms and conditions of sale (including price); components of price, production costs or price lists;

− the territories where Danfoss will provide services;
− the customers to whom Danfoss will sell;
− inviting or encouraging competitors to take certain actions (e.g., “prices are too low” or “margins are compressed’);
− the terms on which Danfoss is dealing with a particular• customer or plans to do so in future;
− information from which prices can be computed; or
− the coordination of price announcements.

• Tell a competitor anything that is not already in the public domain (whether directly or through a trade association), especially information relating to sales, prices, discounts, profits, costs, market shares, territories, bids, terms of business etc. Similarly, you should not accept such information from competitors. Generally, you must have a valid and legal reason to have any contacts with competitors.
• Do anything that could be interpreted as being part of the above prohibited behaviour.
• Use a go-between, such as a trade association or distributor to achieve any of the above.

THESE RULES APPLY EVERYWHERE IN THE WORLD

PRACTICAL COMMUNICATION TIPS:

• Be careful about what you say/write and how you say it!
• Be wary of what you say in public at all times – you never know who is listening!
• Think before you send – electronic documents can be circulated easily!
  – could your message be misconstrued?

AVOID THE FOLLOWING IN DOCUMENTS AND BUSINESS DISCUSSIONS:

• Adding the words “destroy after reading” or similar (it makes it look suspicious);
• Making jokes or amusing remarks regarding a competitor’s price (i.e. making comments about a competitor’s price being “low” may be inadvertently interpreted as an invitation to collectively raise prices together, to that individual, or perhaps his/her boss when the story is repeated!); and
• Making jokes or amusing remarks about conduct “infringing competition laws”, especially when corresponding with colleagues or competitor

COMPETITOR PRICE INFORMATION:

• You should always be prepared to demonstrate where you received competitive pricing information found in your files (paper or electronic).
• You should mark the source of any written or verbal competitive pricing information provided to you.
• If a customer gives you information about competitor pricing, you should write the name of the person who told you the price in your notes next to the price.

MEETING WITH COMPETITORS – BEWARE THE TRADE ASSOCIATION!

• Legitimate business contacts with competitors may occur:
  − contacts with competitors should be avoided unless there is a good and legal justification for the contact;
  − contacts with competitors can easily be misconstrued — minimize or eliminate such contacts as a result;
  − make sure there is a written agenda for a meeting and stick to it.

• Illegitimate activity within trade associations: information exchanges and cartels frequently arise in trade associations or other industry bodies who compile statistics or undertake benchmarking exercises based on member companies’ data;
  can easily lead to situations where confidential commercial matters might be discussed;
  − trade associations therefore tend to be regarded with suspicion by anti- trust/competition regulators.

IF AN INAPPROPRIATE TOPIC ARISES…

• Promptly state your objection to any further discussion;
• If the discussion proceeds, immediately withdraw and request that your departure be noted in the minutes of the meeting (staying could implicate you, whether or not you participated in the debate);
• Promptly give full details to your superior.

Product Specifications

• Product Type: Competition Guidelines Manual

• Classification: Business

• Applicability: Worldwide

Frequently Asked Questions (FAQ)

Q: Why is it important to avoid competition issues?

A: Preventing anti-competitive behavior ensures fair market competition and compliance with global competition laws.

Q: How should I handle interactions with competitors?

A: Only engage in contacts with competitors if there is a legitimate reason, have a clear agenda for meetings, and avoid sharing sensitive information.

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