Anti-Trust Guidelines

Heating, Air-conditioning & Refrigeration Distributors International Anti-trust Compliance Guidelines

All Association meetings are conducted in accordance with HARDI’s antitrust compliance guidelines, which recognizes the importance of full compliance with the antitrust laws applicable to HARDI and its members and the critical role competition plays in our free enterprise system. To summarize, topics of discussion or agreement among competitors which must be avoided at HARDI meetings include:

• Agreements or understandings as to prices, range of prices, pricing methods, margins, future changes in prices, pricing stabilization, costs, surcharges, warranties, discounts and credit terms.

• Agreements or understandings to limit or restrict production levels, production quotas, competitive bidding and limits on sales or supply levels.

• Agreements or understandings to prevent any person from gaining access to a market or to a customer, or agreements to allocate markets or customers.

• Agreements or understandings to refrain from purchasing or selling materials, equipment, services or other supplies from any supplier or to any customer.

• In general, any discussions or actions which would tend to restrict competition between members or competitors, or within the industry generally.

• Members must exercise their independent business judgment in pricing their services and products, dealing with their customers and suppliers, and choosing markets in which they compete.

• These Guidelines do not prohibit a one-on-one discussion between a wholesaler and a manufacturer concerning their commercial relationship and terms and conditions of sale, including pricing, between the parties.

We ask that informal or social discussions at HARDI meetings by the attendees which occur when we’re not in session follow the same guidelines just described.