Anti-Trust and Fair Competition Policy

Document Control Section

Table of Contents

1. Purpose

1.1 GIASA demonstrates zero tolerance towards “unfair methods of competition” and “unfair or
deceptive acts or practices”.
1.2 This policy provides guidance to Associates across GIASA about antitrust and competition laws and
conduct business in fair, ethical and transparent manner.
1.3 It is important that we act professionally, fairly and with utmost integrity in all our business dealings
and relationships; whenever and wherever we operate or engage with competitors, suppliers,
distributors or any other members of our supply chain.

2. Governance 

2.1 Any changes to this policy shall be tracked and documented for future reference and all changes
shall be performed only after prior approval of the Chief Compliance Officer.
2.2 Chief Compliance Officer shall undertake periodic review and update this policy to reflect
applicable law(s) and /or latest notifications released by the regulating authorities from time to time.
2.3 Chief Compliance Officer shall monitor the effectiveness and review the implementation of the
compliance principles set forth in this policy, regularly considering its suitability, adequacy and
effectiveness

3. Applicability

This policy is applicable to all Associates (Associates means on-roll employees of all GIASA entities), Board
Members, contractors, consultants, trainees, service providers of our Company and our subsidiaries,
affiliates, group companies and persons or entities contractually obligated across the globe.

4. Policy Framework 

4.1 Dealing with Competitors
4.1.1 In today’s marketplace, competitors interact in many ways, through trade associations,
professional groups, joint ventures, standard setting organizations, and other industry groups.
GIASA encourages such dealings, provided they are fair, ethical and transparent in nature.
4.1.2 Associates must be aware of antitrust risks in their interactions with competitors and must maintain
caution at all the times during their dealings with competitors.
4.1.3 We must ensure that no collaboration with competitors should violate Competition Laws.
4.1.4 GIASA shall not, under any circumstances, engage in Price Fixing1 with any competitor(s) or
supplier(s). GIASA will establish prices and other terms on its own, without agreeing with a
competitor.
4.1.5 Price Fixing does not relate only to prices, but also to other terms that affect prices to consumers,
and therefore, we shall not disclose any such information to the competitors. This could include
any matters, including but not limited to:
 Present or future prices
 Shipping Fees

1 Price fixing is an agreement (written, verbal, or inferred from conduct) among competitors that raises, lowers, or
stabilizes prices or competitive terms.

 Warranties
 Financing Rates
 Pricing policies
 Promotions
 Bids
 Costs
 Capacity
 Terms and conditions of sales, including credit terms
 Discounts
 Identity of customers
 Allocation of customers or sales areas
 Production quotas
 R&D Plans

4.1.6 Competitive information and/or intelligence, must only be collected through legal and ethical
means such as published news, press releases, information available in the public domain, etc.
4.1.7 If any unauthorized or confidential information is received about a competitor, we must not use
this information and notify the Chief Compliance Officer immediately.
4.1.8 No GIASA Associate shall interact with persons in other entities to control or restrict production,
supply and distribution of GIASA products in the market. Furthermore, any research and innovation
efforts at GIASA must not be influenced by discussions with competitors, that restricts production.

Indicative scenario – A:
Our company monitors competitor’s ads, and we sometimes offer to match special
discounts or sales incentives for consumers. Is this a problem?
No. This information was obtained through information available in the public domain.
Matching competitors' pricing may be good business, and occurs often in highly competitive
markets. Each company is free to set its own prices, and it may charge the same price as its
competitors as long as the decision was not based on any agreement or coordination with
a competitor.
(Source: Federal Trade Commission Official Website)

4.1.9 Associate must never coordinate or collude with competitors by discussing bid amounts for
winning contracts. Such prices or bid amount must always be kept confidential.
4.1.10 Bid rigging can take many forms, but one frequent form is when competitors agree in advance
which firm will win the bid.
4.1.11 Associates must never make plain agreements with competitors to divide sales territories or assign
customers, as such arrangements are essentially agreements not to compete.
4.1.12 Associates must never coordinate or direct competitor to not undertake business with targeted
individual or organization as it amounts to an illegal boycott.

4.2 Dealing with Suppliers

4.2.1 The Anti-trust laws also affect a variety of relationships – those involving organizations at different
levels of the supply chain including but not limited to suppliers, distributors, logistics providers, third
parties, business partners etc.

4.2.2 GIASA encourages arrangements, provided they are undertaken with an intention to reduce cost
or promote efficiencies.
4.2.3 Associates must not enter any formal or informal agreements, with retailers, distributors or business
partners, if the agreement prohibits or appear to prohibit the sale of GIASA products to certain
sections or types of customers.
4.2.4 Associates must refrain from any vertical arrangements with any suppliers if such vertical
arrangement reduces competition among organizations at the same level or prevents new
organizations from entering the market.
4.2.5 Anti-trust issues may also arise if GIASA imposes price or non-price restraints up or down the supply
chain i.e. in dealings with suppliers or dealers which could be in violation of anti-trust laws.
4.2.6 GIASA has a right to choose its business partners. As permitted by applicable laws, GIASA shall be
entitled to enter into exclusive contracts with its Business Partners. However, GIASA Associates must
refrain from any anti-competitive arrangements or agreement.

4.3 Mergers

4.3.1 Mergers may benefit competition and consumers by allowing organizations to operate more
efficiently.
4.3.2 While entering mergers, GIASA shall ensure that all requirements of Anti-trust and Competition laws
are fully complied. Also, GIASA shall make necessary disclosures as mandated by applicable laws
and regulatory authorities while entering mergers.
4.3.3 GIASA prohibits mergers and acquisitions when the effect “may be substantially to lessen
competition, or to tend to create monopoly.”
4.3.4 The principles provided above are an indicative list and not an exhaustive list of all possible
scenarios which could result in violation of applicable anti-trust or competition laws. We ensure
that no business practice is adopted which may be in contravention of applicable anticompetition laws and other relevant guidelines.

5. Exceptions

All exceptions to this policy must be approved by the Chief Compliance Officer.

6. Breach of Policy Principles

Any violation of the principles set forth in this policy by any Employee may have significant
consequences for the Employee and the GIASA Entities, including potential prosecution, fines and other
penalties for improper conduct, as well as imprisonment and/or disciplinary action up to and including
termination.