CEF Antitrust Compliance Policy, Statement and Verbal Reminder

Compliance Policy

Corporate Eco Forum (CEF) is an invitation-only forum for senior executives representing large, influential companies that demonstrate a serious commitment to sustainability as core to business strategy. CEF exists exclusively to provide a forum for senior executives from a diverse group of sectors to exchange best practice insights and build trusted relationships with their peers. While the mission of CEF is designed to avoid any topics that would constitute an antitrust risk, it is the policy and practice of this organization to comply fully with the federal and state antitrust laws and with all other applicable laws and regulations.

Any business forum in which competitors participate carries with it the danger of providing a potential opportunity for activities that may fall within the proscriptions of the antitrust laws. Consequences of failing to abide by the antitrust laws can be severe, including, for example, substantial fines, prison sentences and suits for damages by injured parties. In addition, antitrust litigation is burdensome, expensive and time-consuming for all concerned, even if the outcome is ultimately favorable. Accordingly, members, prospective members and/or the Directors, officers, employees and staff of this organization (collectively, “Participants”) shall abide by the guidelines set forth in this Antitrust Compliance Policy

A. All official CEF meetings have a clear and proper purpose, identified in advance. Written summaries of meetings shall be prepared that accurately reflect the topics discussed.

B. Participants shall not engage in discussions or conduct at social events or meetings incidental to CEF scheduled meetings that would not be proper at the meetings themselves.

C. Participants shall avoid any discussions of competitively sensitive subjects. Therefore participants SHOULD NOT, in our organized meeting sessions, in informal discussions on the side, or in any other setting:

• Discuss prices, rates, or other terms of trade among competitors;
• Discuss employee wages/benefits or any company’s hiring or recruiting practices;
• Engage in discussions that could result in:
• The allocation of customer markets,
• The fixing or stabilization of prices,
• Limitations on production,
• Boycotts of customers, suppliers or rivals, or
• Agreements that would competitively disadvantage certain rivals;
• Discuss proprietary or other competitively sensitive information;
• Discuss or engage in coordinated behavior to maintain prices, profit margins, or stability in an industry;
• Engage in any other anti-competitive behavior or any or any discussion you feel might be inappropriate.

D. Statistical data collection and reporting programs shall relate only to past transactions, and data shall be reported in an aggregate form that does not permit identification of individual transactions or reporting companies. Membership participation in such programs shall always be voluntary.

E. Participants shall be careful in their choice of words and shall never, even in jest, use words that indicate approval of or participation in prohibited conduct. Participants shall avoid conjecture, exaggeration or colorful language that might be misinterpreted.

F. If any subject with any anticompetitive implication or appearance is raised at any meeting, persons attending the meeting or event shall object immediately to a CEF staff person and request that the subject be dropped.

G. Participants shall promptly contact legal counsel for guidance in resolving all questions that may arise concerning the propriety of any proposed program, activity or discussion. 

Click here to download a PDF version of CEF's Antitrust Compliance Policy

The purpose of this meeting is to discuss corporate sustainability/ESG issues. The specific discussion objectives and topics have been shared in advance. While compliance with antitrust and other laws that govern participation in industry meetings is the responsibility of each participant, we ask you to follow both common sense and these simple guidelines to help us conduct our meeting according to good practices, and to ensure that your fellow participants are comfortable attending and actively participating.

Please DO NOT, in our organized meeting sessions, in informal discussions on the side, or in any other setting:

• Discuss prices, rates, or other terms of trade among competitors;
• Discuss employee wages/benefits or any company’s hiring or recruiting practices;
• Engage in discussions that could result in:
• The allocation of customer markets,
• The fixing or stabilization of prices,
• Limitations on production,
• Boycotts of customers, suppliers or rivals, or
• Agreements that would competitively disadvantage certain rivals;
• Discuss proprietary or other competitively sensitive information;
• Discuss or engage in coordinated behavior to maintain prices, profit margins, or stability in an industry;
• Engage in any other anti-competitive behavior or any or any discussion you feel might be inappropriate.

Thank you for following these few simple guidelines. They are provided to set the stage for a successful discussion of sustainability not as a complete list of antitrust “don’ts” or legal advice. Should you have any concerns or questions about antitrust issues, your legal responsibilities, or your participation in industry meetings, you should seek advice from your own counsel.

“A friendly reminder that CEF provides neutral convening space for our members to discuss corporate sustainability/ESG issues and that we adhere to anti-trust regulations. That said, the ultimate responsibility for compliance with antitrust and other laws that govern participation in industry meetings is the responsibility of each participant. While we don’t expect any of today’s discussions to veer into antitrust territory, should that occur we will ask members to cease that line of conversation. We’ve posted a reminder of anti-trust boundaries here for those that need a refresher.”