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Anti-Trust Compliance

Commitment to Antitrust Compliance
The DDG is committed to maintaining fair and competitive practices in the trading and shipping industries, and to adhering to all applicable antitrust laws adopted for these purposes. Pursuant to the DDG Charter, all DDG Members are required, at all times, to adhere to the DDG's Antitrust Compliance Policy, the current version of which is set out below.

Antitrust Compliance Policy
The DDG and its Members are committed to complying fully with all antitrust and competition laws and regulations applicable to DDG activities including, but not limited to, U.S. federal and state antitrust laws, the Enterprise Act 2002, the Competition Act 1998 and European Union directives and regulations.

All DDG meetings, including meetings of the Executive Committee and any Sub-Committees, User Workgroups, Workshops and the Annual and any Extraordinary General Meetings shall be conducted in accordance with this Policy, and all information or documentation produced by the DDG or any of its Members for circulation to Members shall comply with this Policy.

This Policy is intended as a guide to the conduct expected of DDG Members when participating in DDG events and when compiling information or documentation for dissemination to DDG Members. For more detailed information regarding compliance with antitrust and competition laws generally, Members are advised to seek specialist legal advice.

Guide
In all DDG operations and activities (including public and private meetings and social events sponsored or coordinated by the DDG), the DDG and its Members are prohibited from discussing or reaching agreement on or disseminating information relating to prohibited activities.

Prohibited activities include, but are not limited to:
  • any activities which have the purpose or effect of restraining trade or which have the potential to affect or distort competition among individual companies;
  • fixing of terms, prices or rates, which includes discussions and/or dissemination of information relating to pricing policies, current or future prices, price changes, rebates, allowances, costs, terms and conditions of sale, credit or financing terms or any other information which relates to pricing;
  • disseminating, offering or accepting copies of price lists;
  • discussions relating to relationships with particular customers, suppliers or competitors, including discussions regarding the commercial terms of contracts and marketing strategies;
  • discussions relating to market conditions, including production strategies and targets, market share, capacity and inventories and supply and demand projections;
  • any attempt to allocate or divide customers, territories, or markets;
  • any attempt to boycott, black list or refuse to deal with particular customers, vendors or suppliers; and
  • staying at a meeting, or any other gathering, at which prohibited activities are taking place.
All advice to Members, including, but not limited to, suggested standard clauses for charterparties and sales of goods contracts, shall be non-binding and for information purposes only.


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