Purpose
Penanshin Shipping trusts in developing long-term relationships with all its stakeholders and endeavors to create value for them through its fair practices. The Group determines zero tolerance towards unfair methods of competition and unfair acts or practices. This policy provides guidance to all associates across The Group about antitrust and competition laws and conducts business in a fair, ethical, and transparent manner. It is important that we act professionally, fairly, and with utmost honesty in all our business dealings and relationships, whenever and wherever we operate or engage with competitors, suppliers, contractors, or any other members of our supply chain.
Scope and Applicability
This policy is applicable to Allcargo Belgium N.V. and its subsidiaries across all geographies (wherever applicable), together referred to as “Penanshin Shipping” or “the Group.”
Governance
Any changes to this policy shall be tracked and documented for future reference, and all changes shall be performed only after prior approval of the Compliance Officer. The Compliance Officer shall undertake periodic review and update this policy to reflect applicable laws and/or the latest notifications released by the regulating authorities from time to time. The Compliance Officer shall monitor the effectiveness and review the implementation of the compliance principles set forth in this policy, regularly considering its suitability, adequacy, and effectiveness.
Policy Guidelines on Anti-trust/Anti-Competitive Practices
In today’s marketplace, competitors interact in many ways, through trade associations, professional groups, joint ventures, standard-setting organizations, and other industry groups. The Group encourages such dealings, provided they are fair, ethical, and transparent in nature.
Encourage the development and operation of competitive open markets and the liberalization of trade and investment in each country and market in which The Group operates.
Refrain from exchanging information with competitors on individualized intentions concerning future conduct regarding prices, quantities, or other elements of competitive behavior.
Avoid entering into any activity constituting anti-competitive behavior such as abuse of market dominance, collusion, participation in cartels, or inappropriate exchange of information with competitors.
All employees must be aware of antitrust risks in their interactions with competitors and must maintain caution at all times during their dealings with competitors.
Competitive information and/or intelligence must only be collected through legal and ethical means such as published news, press releases, and information available in the public domain.
The Group shall not, under any circumstances, engage in Price Fixing with any competitor(s) or supplier(s). The Company will establish prices and other terms on its own, without agreeing with a competitor(s). Price Fixing does not relate only to prices but also to other terms that affect prices to consumers. Therefore, employees should not disclose any such information to competitors.
While entering mergers, The Group shall ensure that all requirements of Antitrust and Competition laws are fully complied with. Also, The Group shall make necessary disclosures as mandated by applicable laws and regulatory authorities while entering mergers.
While dealing with competitors, never agree to set prices, allocate regions or product markets, or engage in bid rigging. Refrain from exchanging any confidential, price-sensitive, or commercially sensitive information.
Do not take up or involve in any activities competing with the business of the Group.
If any unauthorized or confidential information is received about/from a competitor, we must not use this information and must notify the Legal Department / Compliance Officer immediately.
Breach of Policy
Any violation of the policy guidelines set forth in this policy by any employee or any other persons/entity to whom this policy applies may have significant consequences for the employee and The Group, including potential prosecution, fines, and other penalties for inappropriate conduct, as well as imprisonment and/or disciplinary action up to and including termination.
