11 Code of Conduct Doing it right for our customers Following antitrust laws One way we compete fairly is by following the antitrust laws (sometimes called competition laws) that apply to us. These laws may vary slightly from country to country, but in general they help to protect free and fair competition in the marketplace. Antitrust laws forbid any agreement or understanding that improperly restrains or limits trade, even if the agreement is only implied or verbal. How we own it • Understand the antitrust laws that apply to our business and avoid even the appearance of anticompetitive behavior. • Take care when speaking with competitors. If a competitor raises a potentially anticompetitive topic with you, end the conversation and report it to an attorney in our Law Department right away. • Remember that antitrust laws apply when you interact with AAR’s subsidiaries, customers, third-party business partners and competitors. See the Antitrust Compliance and Hiring of AAR Employees policies for more information. Anticompetitive Practices Here are a few common types of anticompetitive activities: Price fixing: Agreeing with a competitor to raise, lower or stabilize prices. Market or customer division or customer allocation: Dividing customers, territories or markets with competitors. Bid rigging: Coordinating bidding activity with competitors to decide who will be awarded a contract. Boycotting: Agreeing with a competitor to not do business with targeted individuals or businesses. Monopoly: Taking advantage of a dominant market position to dictate pricing or other terms. No-hire pact: Restricting the hiring of employees by AAR or third parties. Steve, who works in supply chain management for AAR, is at an aviation industry conference. He runs into Melissa, who manages suppliers at AAR’s biggest competitor. Melissa mentions that one particular supplier has raised their prices substantially in the last few months. AAR also does business with this supplier, and Steve has noticed the same thing. Melissa says, “Let’s both just stop buying from them. We are their two biggest customers, so they will have to lower their prices to get us back.” Steve isn’t sure how to respond, so he shrugs and says nothing. Is he Doing It Right? No, he is not. Melissa is suggesting boycotting a supplier, which violates antitrust laws. Instead of simply shrugging, Steve needs to make his objection known, leave the conversation immediately and then contact an attorney in the Law Department. In these situations, it is important to clearly state that you do not agree with what has been proposed, and then end the conversation immediately.