Page 19 - Code-Of-Conduct

10. ANTITRUST AND COMPETITION
Freudenberg requests that all managers and associates fully comply with all antitrust and other trade laws which generally prevent the unreason- able restraint and functioning of a free and competitive marketplace. Freuden- berg also adheres to all legislation that outlaws unfair or deceptive trade practices. Freudenberg does not enter into any coordinated or informal arran- gements to boycott customers or other business partners and we have a policy of zero tolerance towards price-fixing, bid rigging, or allocation of customers and markets among competitors.
Freudenberg associates may not discuss or exchange any information with com- petitors regarding:
• Product prices, price changes, price differentials, margins, costs, mark- ups, discounts, allowances, etc.
• Industry pricing policies or practices, price levels, price changes, price dif- ferentials, etc.
• Plans concerning the pricing and marketing of products
• Any bids or Requests for Proposals (RFPs) to which the parties are res- ponding, including pricing or product mix relating to such bids or RFPs
• Information about production capaci- ty and intended adjustments
• New products in development and other confidential strategies
• Allocation of any territories, custom- ers or markets
• Customer specific or transaction spe- cific confidential information
Please clarify any doubts about appro- priate contact and communication with competitors immediately by dis- cussing your concerns with your local senior management or Corporate Legal. Should a situation or conversation arise in which you have any doubt of its appropriateness in this context, you should remove yourself from the situa- tion immediately and report the matter to your supervisor and/or consult the Compliance Office or Ethics Office or Corporate Legal.
19