ANTITRUST COMPLIANCE GUIDELINES
The Board of Directors of the Contract Packaging Association (CPA) has publicly stated its support for the policy of competition served by Federal and state antitrust laws, and its intent to comply strictly with these laws. In support of the Statement, the officers of the Contract Packaging Association make the following requests at this meeting:
ANTITRUST POLICY STATEMENT
The Contract Packaging Association is a not-for-profit society organized to serve and advance the contract packaging industry. Its purpose is to provide a common meeting ground where suppliers and users of contract packaging services can become informed of current industry developments and share professional interests. CPA is not intended to, and may not, play any role in the competitive decisions of its members or their employers, nor in any way restrict competition among users or suppliers in any of the industries it serves.
Through its activities, CPA brings together representatives of competitors in many areas. Although the subject matter of CPA activities is normally technical in nature, and although the purpose of these activities is principally educational and there is no attempt to restrain competition in any manner, nevertheless the Board of Directors recognizes the possibility that the CPA and its activities could be seen by some as an opportunity for anticompetitive conduct. For this reason, the Board takes the opportunity, through this Statement of Policy, to make clear its unequivocal support for the policy of competition served by the antitrust laws and its uncompromising intent to comply strictly in all respects with these laws.
In addition to the CPA's firm commitment to the principle of competition served by the antitrust laws, the penalties which may be imposed upon both the CPA and its individual and corporate members involved in any violation of the antitrust laws are so severe that good business judgment demands that every effort be made to avoid such violation. Certain crimes for which individuals may be imprisoned for up to three (3) years or fined up to $100,000, or both, and corporations can be fined up to $1 million for each offense. In addition, treble damage claims by private parties (including class actions) for antitrust violations are extremely expensive to litigate and can result in judgments of a magnitude which could destroy the Association and seriously affect the financial interest of its members.
It shall be the responsibility of every member of CPA to be guided by the Association's policy of strict compliance with the antitrust laws in all CPA activities. It shall be the special responsibility of meeting chairpersons to insure that this policy is known and adhered to in the course of activities pursued under their leadership.
To assist the CPA staff and all of its officers and directors in recognizing situations which may raise the appearance of an antitrust problem, the Board will as a matter of policy furnish to each such persons the General Rules and Antitrust Compliance. Should questions arise as to the manner in which the antitrust laws may apply to the activities of CPA or any committee thereof, such questions shall be directed to CPA headquarters.
Antitrust compliance is the responsibility of every CPA member. Any knowing violation of the CPA General Rules of Antitrust Compliance or this general policy by an CPA member will result in that person's suspension from membership in the Association, and removal from any office held.
GENERAL RULES OF ANTITRUST COMPLIANCE
The following rules are applicable to all CPA activities, and must be observed in all situations and under all circumstances without exception or qualification other than as noted below:
Address all questions concerning antitrust policy and guidelines to:
Contract Packaging Association
12930 Worldgate Drive, Suite 200
Herndon, VA 20170