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CPS ANTITRUST COMPLIANCE POLICIES AND PROCEDURES It shall be the policy of the Colorado Pharmacists Society (CPS) to be in strict compliance with all Federal and State Antitrust laws, rules and regulations. These policies and procedures apply to all meetings of the Society, and all meetings attended by representatives of the Society. It is the Society’s policy that a copy of these Antitrust Compliance Policies and Procedures be given to each officer, director, committee member, meeting attendees and Society employees annually and that the same be read, or understood at all meetings of the Society. Speakers at any meeting of the Society shall be informed that they must comply with CPS’s antitrust policy. It is the express purpose of this and other meetings of CPS to promote the highest degree of professionalism in pharmacy practice. Discussions involving anti-competitive activity are contrary to this purpose, and will not be tolerated. Therefore: 1. Discussions of prices or price levels whether past, present or future is prohibited. In addition, no discussion is permitted of any elements of a company's operations which might influence price. (e.g., cost of operations, supplies, labor or services, allowance for discounts, terms of sale including credit arrangements, and profit margins and mark ups, provided this limitation shall not extend to discussions of methods of operation, maintenance, and similar matters in which cost or efficiency is merely incidental.)
2. It is a violation of Antitrust laws to agree not to compete, therefore, discussions of division of territories or customers or limitations on the nature of business carried on or products sold are not permitted.
3. Boycotts in any form are unlawful. Discussion relating to boycotts is prohibited, including discussions about blacklisting or unfavorable reports about particular companies including their financial situation.
It is the Society’s policy that any meeting attended by a representative of the Society where discussion can border on an area of antitrust sensitivity, that the representative request that the discussion be stopped and the request be made a part of the minutes. If the discussion continues, the Society’s representative should excuse them self from the meeting and request that the minutes reflect them leaving at that point and the reason they left. Any such instances should be reported immediately to the president and staff of the Society. These illustrations are provided as examples, and are not all-inclusive of potential antitrust violations. Any person or group of persons involved in inappropriate discussion or other activity which may be viewed as a violation of antitrust law will not be allowed to participate in the meeting. Resource: www.nonprofitcenter.com |