Code of Conduct Guidelines
The Medical Device Supply Chain Council ("the Council") and its members are committed to adherence to all applicable antitrust laws governing discussions among competing firms. Accordingly, the Council has adopted the following Guidelines and Code of Conduct.
- All meetings and discussions should further a pro-competitive purpose and not venture into any areas that might be considered anti-competitive.
- Council participants should never engage in discussions about fixing prices or output, rigging bids, or sharing or dividing markets by allocating customers, suppliers, territories or lines of commerce.
- Participants must not agree to undertake any joint conduct with respect to the market or engage in conduct from which an inference of coordination might be drawn.
- Confidential company information should not be discussed. Examples include:
- confidential product pricing
- competitive input pricing (e.g., employee wage information)
- appropriate profit levels
- market allocations
- Exchanges of nonpublic future information should be avoided.
- Competitively sensitive information exchanged within the Council should be disseminated in aggregated or averaged form, and any such information should be gathered by disinterested third parties.