Compliance rules
Compliance with cartel-law regulations
All attendees and staff members must take great care to ensure that in the course of the Conference no breaches of cartel-law provisions take place.
The work done by the joint organisations of the steel industry thrives on representatives from competing undertakings getting together and exchanging information on topics, experiences and objectives of mutual interest. However, this may not lead to a situation where competition between steel undertakings is restrained or excluded to the disadvantage of their customers or suppliers.
At all events, committee meetings and other get-togethers of the organisations, no matters inadmissible under cartel law or otherwise questionable may be dealt with.
Not only explicit agreements, e.g. on quantities, prices or capacities, but also all other forms of cooperation which lead to coordinated action in competition (concerted practices) are inadmissible.
The exchange, discussion or unilateral disclosure of what is referred to as strategic information or sensitive data is prohibited.
It is not a matter of what attendees hope to achieve by their conduct, but whether it is capable of restricting competition or does in fact have a restrictive effect on competition.
Associazione Italiana di Metallurgia’s guidelines on adherence to cartel-law regulations shall be followed in all respects.
Deemed (but not exhaustively) to be strategic information or sensitive topics is, in particular, information that allows conclusions to be drawn about market behaviour:
- Prices, price components, price-related factors, price calculations
and elements of calculation, price rises or price reductions, costs - Production quantities and delivery quantities, quotations, sales
figures, turnover, market shares, customers & clients, suppliers,
exports, destinations, contractual terms - Capacities, capacity utilisation, warehouse stocks and days
of inventory, delivery times, closures, production stoppages,
production restrictions, investments - Future developments of certain products, strategies.
If the meeting chairperson, an association member or another attendee should discover that a breach of cartel-law regulations is manifesting itself, that person must draw the attention of the other attendees to such inadmissibility and make efforts to end the critical conduct. Also in case of doubt as to admissibility under cartel law, the relevant work must cease without delay and legal advice must be obtained.