COMPANY POLICY

Abels Anti-Trust Charter

Last Updated: 14^th March 2023

Anti-Trust Charter – Leading the Fight Against Cartels

Abels supports the adoption of the Anti-Trust compliance program of FIDI. In this connection, FIDI is determined to support the fight against cartels, which restrict competition among suppliers to the detriment of customers.

Membership in FIDI is highly valued and we pledge to abide by the highest ethical standards and to free and fair competition.  This agreement sets FIDI members aside from our moving companies.

What Is a Cartel?

A cartel is an agreement, concerted practice or conspiracy among competitors to fix prices, submit collusive tenders, divide or share markets and, more generally, restrict competition.

A cartel is regarded as the most egregious violation of Anti-Trust laws in most jurisdictions, which may lead to the imposition of significant fines as well as, in certain jurisdictions, criminal penalties.

Abels are committed to legal and ethical behaviour, and to refrain from engaging in any business that will harm the interests of FIDI, other affiliates, clients, or the industry. Abels will take steps to ensure they are fully informed of applicable Anti-Trust laws and regulations in connection with cartel conduct and other Anti-Trust violations, and will monitor their employees and business partners to ensure full and continual compliance.

• Legal compliance

Abels will endeavour to be aware of applicable laws and regulations covering anticompetitive practices in the jurisdictions in which they operate and will obey and uphold those laws and regulations.

Abels will endeavour to be aware of, and comply with, applicable laws and regulations in connection with cartels.

• Ethical behaviour

Abels pledge to take a zero-tolerance approach to cartel conduct.  We will act professionally, fairly and with the utmost integrity in all business dealings and relationships.   

Code of Conduct

By agreeing and committing to this Charter, Abels undertakes to:

Never make direct or indirect (via third parties including agents, suppliers or customers) contact with an actual or potential competitor or other third parties, the object of which is to engage in cartel behaviour.

Never propose or reach an agreement, whether directly or indirectly, formally or informally, with actual or potential competitors, regarding any sensitive competition-related issues, including:

• Fixing prices
• Dividing or sharing markets, customers or territories
• Rigging a competitive bidding process.

Report any indication or initiative of improper anticompetitive business conduct by an actual or potential competitor in accordance to your internal reporting procedure, including but not limited to, reporting to your legal department and/or to the relevant Anti-Trust authorities.

Not to participate in a meeting of a trade association in which sensitive competition-related issues are discussed. If such subjects are raised during a meeting, Abels employees would immediately ask for the discussion to end.  If not, we would leave the meeting and ask for that to be noted in the minutes of the meeting.

Ensure that all internal and external correspondence, including e-mails and texts, and documents, discussions and public statements do not contain any statements that might be misinterpreted by third parties or Anti-Trust authorities and courts in the context of a potential Anti-Trust investigation.

Maintain independent judgment in pricing or selling of any products and/or services.

Limit any information discussed during commercial negotiations, with or disclosed to competitors or other third parties, to that which is strictly necessary for completing or assessing the transaction.

This policy has been approved and adopted by the Board of Abels Moving Services Ltd – 14^th March 2023