ANTITRUST
COMPLIANCE

Coalition for Cyclist Safety Antitrust and Confidentiality Reminder

COALITION FOR CYCLIST SAFETY takes compliance with antitrust laws seriously, including even the appearance of impropriety. Prohibited discussion topics apply to COALITION FOR CYCLIST SAFETY meetings as well as social gatherings incidental to COALITION FOR CYCLIST SAFETY-sponsored meetings. Antitrust violations can result in severe criminal and civil penalties for trade associations, companies, and individuals.

This list is not exhaustive and is not intended to address activities other than COALITION FOR CYCLIST SAFETY-sponsored meetings. To ensure continuing compliance, you are reminded of the following key provisions:

• COALITION FOR CYCLIST SAFETY members will prepare agendas that must be strictly adhered to during meetings.
• COALITION FOR CYCLIST SAFETY members will prepare minutes for all COALITION FOR CYCLIST SAFETY Steering Committee and membership meetings. Member organization representatives at the meetings should refrain from making “unofficial” minutes.
• There should be no discussion of any elements of pricing, such as:
  • Allowances or discounts;
  • Terms and conditions of sale, including warranties and credit arrangements;
  • Profit margins and markup.
• There should be no conversations about limiting or expanding capacity or output, future product or advertising plans, allocation of markets, or any other competitive or antitrust-sensitive subjects.
• There should be no conversations relating to refusals to deal with suppliers or other companies – e.g., no discussions about black-listing or tactics for dealing with particular companies.
• There should be no conversations about company or competitor plans for product design, production, distribution or marketing, including proposed territories or customers.
• There should be no secret meetings held around the time of scheduled meetings or at any other time if the discussion is to cover antitrust-sensitive subjects.
• Either COALITION FOR CYCLIST SAFETY or member company legal counsel should be consulted if there is any doubt about any element of COALITION FOR CYCLIST SAFETY’s program or discussion. Discontinue discussions and consult with counsel when any perceived antitrust compliance issues arise.

Confidentiality

All meetings and conference calls hosted by COALITION FOR CYCLIST SAFETY and information provided by COALITION FOR CYCLIST SAFETY in connection with these events as well as any other COALITION FOR CYCLIST SAFETY communications transmitted by mail or electronically are intended exclusively for the benefit of our members and their employees. Unless prior approval of COALITION FOR CYCLIST SAFETY is obtained, meeting discussions, company position statements, drafts of comments or correspondence, or other related information should not be disclosed to third parties, including the media.