Antitrust Policy
Purpose:
To establish the general rules, principles, guidelines, and commitments related to full compliance with competition laws, ensuring the ethical development of CPFL's activities with active involvement and cooperation with the relevant authorities.
Implementation:
This Policy applies exclusively to Cramlington Precision Forge Ltd. (CPFL). All employees (permanent, temporary, and trainees), third parties acting on behalf of CPFL, interns, directors, and officers must comply with this Policy and all related regulatory documents, even if the country in which they work or reside has more lenient rules or practices. Conversely, if the country has stricter rules, the stricter rules should apply. In all cases, the highest and most restrictive standard must always apply.
References:
– Code of Conduct
– Human Rights Policy
– Risk Management Policy
– Anti-Corruption Policy
Context:
Most countries where CPFL operates have competition protection laws designed to prevent practices that restrict trade and/or free competition, such as forming cartels and exercising dominant positions in the market. Violation of these competition laws can lead to serious consequences for CPFL and its representatives. Therefore, all representatives and third parties acting on behalf of CPFL must comply with the rules of conduct described in this Policy.
Definitions:
Associative Contracts: Contracts with a total aggregate term of two years or more, entered into between competitors in the market that involve sharing risks and results of the economic activity.
Competition Laws: Refers to laws and regulations governing the prevention and suppression of violations against economic order and free competition in the countries where CPFL operates.
Competitive Sensitive Information: Non-public information related to CPFL's commercial activities, including sales conditions, pricing, costs, strategic plans, and other commercially sensitive data.
Competitor: Any individual or legal entity that supplies or could supply the same or substitute products as those sold by CPFL.
Illegal Behavior: Any behavior that has the potential to impair free competition, dominate a relevant market, increase profits arbitrarily, or exercise market power abusively.
Market Power: The ability of a company to reduce its supply or raise its prices above competitive levels without losing customers.
Public Authority: Any authority, agency, or representative of the state at any municipal, state, or federal level.
Representative(s): Directors, board members, committee members, employees, managers, external advisors, lawyers, consultants, and any other individuals or legal entities acting on behalf of CPFL.
Third Parties: Suppliers, customers, agents, and traders who have relationships with CPFL.
Principles:
In line with our value “Act with Integrity,” free competition is essential for promoting a fair and healthy business environment. CPFL is committed to maintaining a business environment free from fraud and manipulation, whether in bidding processes or contracts with the public or private sectors. Compliance with competition laws reinforces CPFL's commitment to acting as an effective and responsible institution.
This Policy aligns with CPFL's Code of Conduct commitments, including:
Zero tolerance for corruption and bribery.
Protecting CPFL's reputation.
Prioritizing risk management and internal controls.
Acting with legality, formality, transparency, and accountability.
Guidelines:
The primary objective of this Policy is to prevent and repress violations of economic order, guided by the principles of freedom of initiative, free competition, consumer protection, and the repression of economic power abuse.
CPFL representatives and third parties must act independently when defining prices, production levels, sales, and marketing strategies, and when selecting customers and suppliers.