GREIF, INC.
DELAWARE, OH

In the case of labor costs in multi-employer bargaining situations, consult with the Greif Legal Department. Do object to any dealings or discussions involving competitive information by stating“It is improper to discuss such matters” and remove yourself from the conversation.Immediately follow up such dealings or discussions by consulting with the Greif Legal Department and send all documents related to such matters to the Greif Legal Department. Minimize informal contacts between competitors, such as plant visits between company engineers, except as reviewed and approved by the Greif Legal Department.While certain activities, such as safety and environmental benchmarking are appropriate, competitor contacts, no matter how laudable, raise sufficient risks of misperception that utmost care must be taken. Forward to the Greif Legal Department any correspondence, email or other written communication received from a competitor that discusses competitive information. Do not select distributors and other customers on the understanding that products will be resold only at prices specified by Greif. Any exclusive dealing arrangement, requirements contract, reciprocal dealing arrangement, or requirement that a customer must purchase from Greif other unwanted products or services (commonly called a tying or bundling arrangement) must be reviewed by the Greif Legal Department. Any communication with a competitor/supplier or competitor/customer must be in the context of a legitimate, good faith interest in buying or selling. This does not mean that every conversation must result in a purchase or sale.For example, company X may call supplier Y to explore a purchase, but learns that there is no product availability or the price isn’t right.However, the context is that company X had a genuine, legitimate interest in buying.This is to be contrasted with a “dummy” call where there is no interest in buying, but the call is made primarily to obtain market information. B.     Product Trades Discussions between trading parties should be limited to information necessary to complete the particular trade transactions.Never exchange “competitive intelligence” during discussions about trades or products.This includes discussions about general market trends, supply or demand, pricing, or other competitors that is not related to the bona fide needs for the trade.This means you cannot even ask simple questions like “How is business” or “What are you seeing in the market these days”. Trades should be documented in writing, which should include a specified duration for the trade.Trade arrangements should be reviewed regularly to determine if there is a business justification to continue the trade relationship with a competitor. No employee may join any trade association, multi-employer group or other organization without approval by an officer of Greif or that employee’s Business Unit manager Attendance by an employee at a trade show, trade association meeting and/or industry-wide meeting or conference must be reviewed by an officer of Greif or that employee’s Business Unit manager for appropriateness.Particular care should be taken if meetings involve personnel with pricing authority.Industry pricing, market trends, output, and other sensitive competitive topics should never be mentioned or discussed in any fashion.If pricing or any inappropriate topic is raised by a competitor, Greif personnel should object and, if necessary, leave immediately.The Greif Legal Department should be contacted immediately whenever improper matters are discussed and provided with any relevant documents Special care should be taken when making presentations at trade association or industry meetings and conferences or trade shows, especially on topics with competitive sensitivity (for example, prices or trends, capacity, operating rates, costs, or market conditions). If the presentation is on a topic of competitive sensitivity, that presentation should be reviewed by the Greif Legal Department and the legal counsel for the group producing the event. The actions of agents can create the risk of antitrust litigation, both criminal and civil.Greif should encourage its agents to adopt suitable antitrust compliance guidelines and should consider the existence and effectiveness of such guidelines in evaluating the performance of their agents.In the case of agents that serve multiple companies in the same industry, such compliance guidelines should specifically address the special challenges of such relationships, including safeguards against the flow of information among competitors that might be portrayed as reducing competition. This Policy is focused primarily on conduct and circumstances that relate to price fixing, but all employees must remain mindful of and comply with laws pertaining to price discrimination (known as the Robinson-Patman Act), refusal to deal or boycotting of customers, product tying arrangements, exclusive dealing arrangements and other applicable laws.You should always consult with the Greif Legal Department with any questions regarding these matters and in any situation that appears to have the potential to violate antitrust laws. Statistical reporting is one of the core functions of a trade association.AF&PA’s statistical reports provide substantial benefits to association members by providing accurate and timely information that is highly useful for sound business planning.At the same time, under some circumstances statistical reporting programs can give rise to antitrust concerns.Accordingly, these guidelines are designed to ensure that AF&PA’s statistical reporting system does not create antitrust problems. No antitrust concerns are presented by statistical reports wherein: (a) the data is at least three months old, (b) the data is aggregated from at least five reporting companies, and (c) no company accounts for more than twenty-five percent of the aggregate data in any category.Where only some data categories in a report meet these requirements, the compliant data categories may be cleared without review, but noncompliant categories must receive legal review.Any report that provides data on a company-specific basis is inherently more likely to raise antitrust concerns and therefore must be carefully reviewed by counsel