Introduction

CeCo Management Ltd., (“CeCo”) is committed to full compliance with all applicable antitrust laws.

Referred to in this policy, an Attendee is defined as the company or other legal entity which is the employer of the participant or if the participant has no employer, then the Attendee is the natural person who participates.

CeCo expects Attendees at the Global Carbon Congress (the “Event”) to be aware of, understand, and comply with all anti-trust laws and not to use the Event to co-ordinate their commercial activities.

Any activity that could create an appearance of a restriction upon or a distortion of competition must be avoided.

CeCo reserves the right to ask Attendees, who it believes do not comply with anti-trust laws, to cease and desist and/or to leave the Event.

The Global Carbon Congress was created for all purchasers, traders and producers to confer on various aspects of the coal market together in one place.

Members of the Press are not permitted to attend the Global Carbon Congress.

Topics of discussion include the state of demand and supply and future directions influencing and presenting opportunities in the Industry in which all the Attendees operate.

Other matters include employment issues, environmental considerations and foreign exchange variability.

The Global Carbon Congress stands for and promotes the individual’s right of free speech and civil liberties to the maximum extent permissible under the laws of the state in which the Event takes place each year.

The Attendees and CeCo intend to provide a venue for free and honest discourse.

Parts of the Global Carbon Congress operate, where indicated, under the Chatham House Rule pursuant to which Attendees are free to use the information received, but neither the identity, nor the affiliation of the speaker(s), nor that of any other participant, may be revealed.

The following policy detail shall govern the operation of the Event by CeCo and additionally states the conduct of Attendees which will not be permitted by CeCo, so that compliance with applicable antitrust laws is maintained and how behaviour of Attendees acting in contravention of this policy will be addressed.

This policy is made available to registered Attendees prior to the Event at www.carbon-congress.com and is printed in the Event programme and is available on request by registered delegates by writing to info@carbon-congress.com.

 

 

Antitrust Compliance Policy

1. Participation in the Global Carbon Congress is inclusive and available to all producers, users, traders and buyers of coal and coal products (the “Industry”), only subject to the applicability of any economic sanctions.

2. Applications for participation in the Global Carbon Congress are processed in the order in which they are received.

3. No maximum or minimum limits on production or consumption or turnover criteria stipulations are applied in the process of acceptance of applicants who enquire about attendance or who register their interest in the Event.

4. The number of Attendees permitted to attend the Event is limited only by the capacity of the venue reserved for the Event.

5. Attendees are expected to proactively promote the development of the Global Carbon Congress participation. Where there is a company or individual who does not already attend the Global Carbon Congress, but who’s participation would be seen by the existing Attendees to be of benefit, then the Attendees will actively promote the Event to any such executives by bringing the Event to the attention of the omitted company/individual(s) for the purpose of their potential inclusion in future occurrences of the Event.

6. Attendees will not be permitted to use the Event to engage in any explicit or implicit activity or practice which would amount to price fixing or price collusion, or behaviour contrived or likely to affect price or production and/or sharing of markets, products, customers or sources of supply.

7. Attendees will not be permitted to use the Event for the purpose of benchmarking or exchanging non-public or confidential, commercially sensitive individual company information or for highlighting any price that it believes the market should maintain or to propose any price increase or price decrease.

8. Attendees will not be permitted to use the Event engage in colluding or attempting to collude to fix discounts, pricing methods, profits, profit margins or share information on production cost data, production, plans, market shares, distribution, volumes, sales territories or markets, allocation or territories or customers or terms or conditions of sale of products, or services.

9. The Event agenda will be set taking input from Attendees before and after the Event with periodic review at intervals during the year.

10. CeCo will confer with experts industry-wide to compile data on demand and supply in advance of the Event.

11. The figures will be submitted to the moderators at the Event such that the information will be placed in the common domain within the Event and accessible equally to Attendees who are new entrants as well as to Attendees who are established participants in the Industry.

12. The data will be the basis for open discourse between purchasers, producers and traders and it will include outlooks of demand and supply positions.

13. This information will additionally facilitate the evaluation of issues concerning the global business of coal and other carbon products.

14. CeCo will provide a platform for the dissemination of the contributor’s data to Attendees.

15. The Global Carbon Congress presentations and findings will be distributed to all Attendees at no additional cost.

16. A summary of the findings from the workshops will be available to qualifying non-Attendees from the Industry for a price of €4,000 excluding any applicable taxes. This price will be subject to alteration by CeCo from time to time within reasonable limits.

17. Attendees may be asked to participate in workshops at some instances of the Event.

18. When asked to participate in workshops Attendees will be expected to actively  engage in their chosen workshop or in the workshop to which they will be assigned by CeCo.  

19. CeCo will solicit volunteers from the participants to act as facilitators of each workshop on a random basis without contrivance or manipulation.

20. Facilitators will take the minutes of the workshops for presentation in a general Attendee session.

21. Facilitators’ duties will include drawing the attention of participants to paragraphs 6, 7 and 8 of this policy.

22. Any Attendee which CeCo believes has behaved explicitly or implicitly in a manner not permitted by CeCo as described in paragraphs 6, 7 and 8 of this policy will be removed from the Global Carbon Congress without delay and their attendance payment will not be refunded.

23. Any Attendee who is aware of, or suspects an Attendee to be acting in in a manner not permitted by CeCo as described in paragraphs 6, 7 and 8 of this policy may report it to CeCo.

24. If an offender or suspected offender is an employee of a company, the employer will be informed immediately.

25. An individual or a company whose employee or representative is believed by CeCo to be acting in in a manner not permitted by CeCo as described in paragraphs 6, 7 and 8 of this policy may make a written submission to CeCo explaining the actions of its employee/ representative and detailing, if appropriate, any actions taken regarding the employee/ representative in respect to the employee/ representative proposed attendance at subsequent meetings of the Global Carbon Congress together with an affirmation of the company and its employees/ representatives’ commitment to comply fully with applicable antitrust laws.

26. The submission will be given full and fair consideration before a final decision is made by the CeCo regarding the participation of the Attendee at future meetings of the Global Carbon Congress.

27. Any Attendee which CeCo believes to be in breach of the price fixing/collusion rules and regulations on a subsequent or second occasion will be omitted from all Global Carbon Congress Events indefinitely.

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