Integrity Standard - Fair Competition

Policy:
The Company is committed to a policy of vigorous, lawful, and ethical competition which is based on the merits of our products and services. We will maintain the trust of our customers and providers by developing and providing high-quality products and services in a fair, ethical, and legal manner.

We will maintain our customer's trust by striving to ensure that our sales materials, advertisements, and other communications accurately and fairly describe our products and services.

We will promote our products and services through fair and accurate comparisons with our competitors.

It is the policy of the Company to comply with all applicable antitrust and competition laws. These laws are very complex, but, in general, they prohibit agreements or conduct that may restrain trade or reduce competition. They are intended to provide a variety of products and services at competitive prices.

• We will avoid all contracts, agreements, and understandings which unlawfully reduce or eliminate competition or the production or sale of products or services.
  
• We will refuse any agreements with competitors to establish or fix prices or to divide or allocate markets either by market segment, geography, or by any other means.
  
• We will exercise special care to ensure that our discussions and activities with representatives of other companies are in compliance with antitrust laws.
  
• Employees who have questions about potential antitrust implications or antitrust practices should contact the Legal Department.

We will compete fairly. Information about competitors, customers, and providers is a valuable asset in a highly competitive market. However, no illegal or unethical means of obtaining this information will be tolerated. No information should be sought or used that would violate antitrust laws or laws and contracts protecting proprietary data.

Question & Answers

Q: A representative of one of our competitors proposes that we both freeze our prices for one of our products for a six-month period to show our mutual commitment to restraining health care costs. The other company's representative says this is legal because we are limiting the price we will charge consumers. Is it legal?
A: No. It may be illegal. Maximum price fixing agreements may be just as illegal under the antitrust laws as minimum price fixing agreements. You should avoid any discussion of prices with competitors and consult with the Legal Department anytime you receive a similar proposal.

Q: Do I have to have to give a specific reason for refusing to do business with a particular producer, vendor, or consultant?
A: We have broad discretion to decide with whom we will do business as long as we have legitimate business reasons and are not engaged in anti-competitive practices. If you have any questions about whether a particular practice is anti-competitive, contact the Legal Department.

Remember, if you do not understand, or if you have any questions concerning, this Integrity Standard or any other part of the Code, contact your Supervisor, a higher level Supervisor, any of the Corporate Resources or call the Corporate Integrity HOTLINE
(1 800 838-2552).

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