Overview

The SNF Global Antitrust and Competition Policy aims to promote fair competition, prevent monopolistic practices, and protect consumer interests within SNF’s operations worldwide. This policy ensures a level playing field for all market participants while encouraging innovation, economic growth, and efficiency.

DEFINITION OF ANTITRUST AND COMPETITION

Antitrust refers to laws and regulations that promote competition and prevent anti-competitive behavior, including monopolies, price-fixing, market allocation, and unfair trade practices. Competition refers to multiple market participants, offering consumers various choices and driving innovation and efficiency.

COMPLIANCE WITH ANTITRUST LAWS

SNF shall fully comply with all relevant antitrust laws and regulations globally in its operating jurisdictions.

SNF will establish mechanisms to monitor changes in antitrust laws and ensure ongoing compliance.

PROHIBITION OF MONOPOLISTIC PRACTICES

SNF shall not acquire or maintain a dominant position in the market through unfair means, such as predatory pricing or tying arrangements.

SNF will abide by merger control regulations, subjecting mergers and acquisitions to scrutiny and approval by the relevant regulatory authorities to prevent a substantial lessening of competition or the creation of a monopoly.

PRICE AND MARKET MANIPULATION

SNF shall not engage in agreements or collusion with competitors to fix prices, limit production, or allocate markets.

SNF shall not collude with bidders to manipulate the outcome of a bidding process.

SNF will not engage in agreements with competitors to divide markets or customers, limiting competition and consumer choice.

ABUSE OF INTELLECTUAL PROPERTY RIGHTS (IPR)

SNF shall not abuse its intellectual property rights, such as using patents to exclude competitors or hinder innovation.

If SNF holds Standard Essential Patents, it shall license them on fair, reasonable, and non-discriminatory terms to promote competition and prevent the creation of patent monopolies.

CONSUMER PROTECTION

SNF shall not engage in false or misleading advertising that misrepresents the features, benefits, or quality of its products or services.

SNF will not engage in practices that harm consumers, such as false claims, unfair pricing, or anti-competitive behavior.

SNF shall ensure the protection of consumer data and privacy, adhering to strict data protection regulations.

ENFORCEMENT AND PENALTIES

SNF shall establish mechanisms to enforce this policy and ensure global compliance with antitrust and competition laws.

Violations of this policy by SNF or its employees may result in disciplinary action, legal consequences, fines, injunctions, disgorgement of profits, or any other appropriate legal remedies.

PUBLIC AWARENESS AND EDUCATION

• SNF shall conduct regular public awareness campaigns to educate consumers and stakeholders about their rights and the importance of fair competition.
• SNF will support initiatives to enhance the capacity of regulatory bodies and promote research on emerging competition issues.

The SNF Global Antitrust and Competition Policy reaffirms SNF’s commitment to fair competition, consumer welfare, and compliance with antitrust laws globally. By adhering to this policy, SNF can contribute to a vibrant, innovative, and competitive marketplace that benefits consumers, businesses, and the overall economy worldwide.