Antitrust Policy

Legal Guidelines

PPC Member Activities

The Paperboard Packaging Council (“PPC” or “the Council”) has in effect an Antitrust Compliance Policy (“Policy”). The policy is intended for the guidance of PPC member company representatives, officers, directors and staff, when engaged in any activity conducted in the name of, or on behalf of, the Council. All such persons are expected to be familiar with the Policy and to follow it both in letter and spirit.

The following cautionary statements are taken from the full Policy and are intended to be used as a quick reference tool. This document is not a substitute for the full Policy, which is available from the Council’s office and with which all are expected to be conversant. At all Council meetings and events, including informal gatherings before, during or following such meetings and events, PPC members, their representatives and guests will not discuss any of the following competitively sensitive topics:

  1. Current or future prices, price levels, costs or profit margins.
  2. What is a fair or rational profit level.
  3. Actions which could lead to standardizing or stabilizing prices.
  4. Pricing or bidding methodologies or procedures.
  5. Pricing practices or strategies, including methods, timing or implementation of price changes.
  6. Whether or how prices, warranties or other terms of sale are advertised.
  7. Cash or any other discounts, rebates, service charges or other terms and conditions of sale.
  8. Credit terms.
  9. Product warranty terms.
  10. Actual, planned or projected production, production capacity or capacity utilization.
  11. Project demand.
  12. Confidential company plans for new products.
  13. Dividing or allocating geographic or product markets or customers.
  14. Company market share information.
  15. Whether or on what terms to do business with a supplier, competitor or customer.
  16. Whether or on what terms to solicit other companies’ employees for employment.
  17. The business practices of individual firms.
  18. The validity of any patent or the terms of any patent license.
  19. Ongoing litigation, unless being reported upon by PPC’s General Counsel.

We hope the above rules will be helpful as you participate in PPC meetings and other activities. If you have any questions about antitrust compliance, do not hesitate to contact PPC’s General Counsel:

Michael Deese
PPC General Counsel
Howe & Hutton, Ltd.
Tel: (202) 466-7252 x103
Email: cmd@howehutton.com