THE SPIRIT & THE LETTER
The GE Aerospace Way
•
We believe in a free and competitive marketplace. We comply with
antitrust and competition laws in all our activities.
•
We must never enter into improper agreements with other companies
to fix prices or terms to be offered to customers, allocate markets or
customers, or manipulate the bidding process.
Integrity in Action
Q:
I’m talking to a customer, and he is proposing to show me a
competitor quote. What should I do? Can I discuss or accept
copies of competitor quotes from the customer?
A:
It is a normal part of negotiations for a customer to make statements
regarding competitor pricing and other commercial terms and ask
GE Aerospace to improve its offer. However, if a customer offers to
give you a competitor’s document, before accepting you must ask if
the customer is allowed to provide the document. Even if the customer
says it is allowed to provide the document, you must not accept any
document that is marked “Confidential”, “Subject to Nondisclosure
Agreement” (or similar markings) or that you believe to be confidential.
If you receive competitive information, you must submit it (including
any documents) in the Competitive Information Reporting System
(CIMS). You should always contact your organization’s legal counsel
or compliance representative if you have any questions or concerns.
Remember that time sensitive reporting requirements can exist.
Fair Competition
We do not cheat to compete.
Your Role
•
Do not propose or enter into any agreement or
understanding with any competitor about any aspect of
competition between GE Aerospace and a competitor,
including agreements on pricing, bidding, deal terms,
wages or the allocation of markets or customers.
•
Do not propose or enter into any agreement with any
other party regarding whether or how to bid.
•
Avoid contacts of any kind with competitors that
could create the appearance of improper agreements
or understandings. Actively disassociate yourself
from any situations in which improper agreements or
information sharing between competitors are raised,
and promptly inform legal/compliance.
•
Understand and follow your business’s specific
guidelines about contacts with competitors,
obtaining and handling competitive information, and
participating in trade and professional associations.
•
Do not provide, receive or exchange any competitively
sensitive information including proposals in their
entirety or selected sections with any other offeror, a
competitor or its representative, whether in person,
electronically or at an industry meeting.
•
Do not enter into discussions or agreements with other
companies not to hire or solicit each other’s employees,
and do not discuss wages or benefits with other
companies who compete for the same talent pool.
11
Policy Spotlight
Be careful in all interactions
with competitors to avoid
even the perception of
an improper agreement.
Unspoken or implied
agreements—simply the
appearance of unfairness or
deception—can give rise to
reputational harm and legal
liability, including significant
fines and even jail time.
Help Corner
S&L Fair Competition Policy
