Competition Policy

CT Holdings and Services Limited (CTHS) meetings and events (Events) serve legitimate and useful functions. However, they also provide an opportunity for competitors to meet. To prevent potential violation of the Competition Act 1998, the following guidelines, which are not intended to be exclusive, should be observed.

• All CTHS Events shall (where practical) have a written agenda prepared and circulated in advance. The agenda shall be as specific as possible.
• Participants should conduct themselves as if the particular meeting was being recorded or open to the public.
• Participants should raise with the Chairperson any concerns they may have that “competitive situations” are being discussed or commercially sensitive information is being disclosed in any CTHS meeting or event. The most sensitive category of commercial information, that it will rarely if ever be legitimate to exchange, is information relating to the future commercial intentions of an individual participants (in particular price), or non-historic information (a rule of thumb is less than 3 months old) from which its future intentions can be deduced. If deemed necessary the Chairperson should suspend or terminate discussions on the topic causing concern.
• If necessary a participant should leave any meeting, and ensure their departure is minuted, if they have concerns that “competitive situations” are being discussed or commercially sensitive information is being disclosed, if the Chairperson has not taken action to end the discussion or address any concerns raised despite being asked to do so. The participant leaving the meeting should also report the incident to their legal advisers as soon as possible.
• Participants should refuse to attend “fringe” or “secret” meetings with competitors held at the time of scheduled CTHS meetings or events.
• Participants should follow these rules even in the context of social interactions around scheduled CTHS meetings or events, and in particular must act as though everything they say is being recorded or open to the public. Participants must immediately close down any inappropriate discussions, and report their concerns to a CTHS representative and/or their own legal advisers.

Review

This Competition Policy is reviewed at least annually by the CTHS Board.