This program is being conducted by ELFA in accordance with ELFA’s Antitrust Compliance Program. It has been and is ELFA’s policy to comply fully with the antitrust laws, and ELFA officials and staff are required to conduct themselves so as to avoid even the appearance of anticompetitive behavior.

Under ELFA’s Antitrust Compliance Program, no action or subjects that would have the purpose or effect of restricting competition may be considered, discussed or acted upon by ELFA officials or staff at meetings or during social gatherings incidental to meetings. There cannot be a discussion, other exchange of information or action on the following subjects at this meeting:

1. Any agreement, understanding or arrangements on how, why and what level companies should set their fees and prices.
2. Individual or specific company fees and prices or any element of individual or specific company price or pricing policy, including price changes, price levels, price differentials, markups,margins, profits, discounts, allowances or credit terms.
3. Boycotts or group refusals to deal with companies or individuals.
4. Arrangements to limit supply or to restrict the products or services that individuals or companies may provide.
5. Agreements to divide, limit or assign markets or territories in which individuals or companies may provide products or services.
6. Plans to allocate customers to whom individuals or companies may provide products or services.
7. Arrangements that restrict truthful advertising or other methods of competing for business.

The ELFA Antitrust Compliance Program is designed to protect ELFA and all participants in ELFA activities by helping to prevent the potential for antitrust problems and unnecessary litigation.