All participating members must take care to inform themselves of and comply with Competition Law and its requirements. Actions taken in an Association could be construed by competition authorities as part of a pattern of activity, constituting a competition infringement. The IFFAA and all members hereby agree to comply with the following:

The IFFAA and all members must maintain strict compliance with Competition Law. The members and meeting attendees must at all times exercise extreme care to avoid not only violations of law, but also anything that might raise suspicion of such violations. The Chairperson will remind participants at the outset of each meeting that these competition law guidelines apply.

o Participants cannot discuss, share, coordinate or agree on materially non-public information. This includes information on items such as the prices, investment plans, bidding, marketing, selection of customers, etc.

Examples:

DON’Ts:

• No exchange of:

o Specific commercial information

e.g. on specific product margins, profitability of specific segments, on individual customer relations, suppliers, individual transactions, individual agreements, specific pricing formulae, etc.

o General (confidential) commercial information on the company’s commercial conduct or its position in competition or its strategy

e.g. on company strategies on margins, procurement/personnel costs, cost structures, customers, internal price setting systems, discounts, contractual conditions etc.

o Confidential financial information about third parties

e.g. liquidity, exposure, etc.

• No coordination of future strategies & investments

e.g. on costs, price negotiations, discounts, etc.), research and development expenditures

DO’s:

• Publicly available information

e.g. market knowledge, press articles/statements, etc.

• General, anonymized, aggregated data

e.g. statistics which are not company-related, etc.

• Information on standard market practices, trends or conditions or general market development without referring to specific company-related information e.g. general industry trends on how to embed certain business areas in general, general discussion of potential corporate structures, general exchange on products, industry challenges in general and potential causes, industry initiatives, etc.

o All participants must make sure to understand the full range of information not to be shared under UK Competition Law and comply with such. Any participants with questions should consult their own legal.

No member shall be under obligation to act upon any advice, recommendation or decision emanating from the Association’s meetings.

Conflicts of Interest. Whenever a Member has a personal or professional interest directly or indirectly in a matter to be discussed at a meeting, the Member concerned shall declare that interest at or before discussion begins on the matter

The Director is responsible for maintain the Association’s registration with the Information Commissioner’s Office (ICO)

All members must adhere to General Data Protection Regulation (GDPR). In short, this means no discussion of specific information pertaining to companies or deals.