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.
Meeting agendas should be pre-approved by counsel and the topics for discussion should be described in specific terms.
Participants should not stray into topics that are outside the scope of the agenda.
Counsel should be present at all meetings, particularly where legally sensitive topics may be discussed.
Meeting minutes should be kept that accurately describe any actions taken.
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:
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.
