Context

Through Commercial Insight and Social Impact, IGD works to drive change that makes a tangible difference in the food and consumer goods industry. Commercial Insight uses in-depth commercial understanding to uncover rich and visionary data and insights – leading to actionable solutions for success. We reinvest our revenue into Social Impact to address relevant issues, aimed at uniting and mobilising the industry as force for good.

Involvement in IGD is open to all players in the industry on the basis of non-discriminatory, transparent and objective criteria.

The policy of IGD is to ensure that in the pursuit of its mission it complies with all competition laws, whether domestic or foreign, which apply to its functions anywhere in the world.

This Competition Law Compliance Policy governs the conduct of stakeholders’ (i.e. customers, suppliers and working group participants) dealings with IGD within the framework of IGD’s mission. IGD expects all its stakeholders to comply with the Policy, and not to prejudice any of the aims or activities of IGD by any departure from it.

General

Meetings of competitors under the guidance of IGD are not prevented by competition law. However, IGD stakeholders must not use the forum provided by IGD in order to coordinate their commercial activities. Each IGD stakeholder must exercise its independent business judgment in pricing its products and services, dealing with its customers and suppliers, and choosing the markets in which it will compete. Any activity that could create even the appearance of a restriction or distortion of competition must be strictly avoided.

Individual Responsibility

This document was prepared for IGD and does not constitute legal advice to its stakeholders. Whilst IGD expects each stakeholder to comply with this Policy in the course of its dealings with IGD, each stakeholder is responsible for its own competition law compliance and should seek independent legal advice relevant to their individual circumstances. This is not a comprehensive record of all possible competition law obligations.

Discussion Topics

Competition law prohibits the sharing of commercially sensitive and current market information which competitors normally keep secret. It is impossible to provide an exhaustive list of objectionable discussion topics, as the competitive significance of many issues is dependent upon the context in which they are raised. However, IGD prefers to take a cautious approach in relation to competition law issues. Therefore, no commercial topics outside the scope of IGD’s mission should be discussed, acted upon, or even considered, at IGD meetings and gatherings.

In particular, this Policy prohibits any sharing of information within the framework of IGD’s mission between its stakeholders that might constitute or imply an agreement or concerted practice concerning current or future:

1.  prices or price factors, including discounts, rebates, and reductions;
2.  specific costs and demand structure;
3.  profits and profit margins;
4. output, yields and sales;
5.  market shares and sales territories;
6.  investments and marketing plans;
7.  bidding strategy;
8.  credit conditions or any other terms or conditions of sale;
9.  exclusionary practices;
10.  selection, rejection, or termination of customers or suppliers (including contractual terms).

An agreement may include an oral or informal agreement, whether legally binding or not.

Exchange of Information

IGD stakeholders shall not share individualised, current or prospective commercial information, particularly with regard to prices, discounts, costs, investments, output or sales, capacities, customers, or market shares, other than information already legitimately in the public domain.

In general terms, stakeholders should only share aggregate public historical data for the purposes of advancing IGD’s mission.

Meetings

If a meeting or discussion involves practices contrary to this Policy, IGD will terminate that meeting or discussion immediately. A stakeholder should invite IGD to terminate a meeting if the stakeholder feels that the Policy has been breached.

Review and Monitoring

This policy was last reviewed and approved by the Board of Trustees on 22 November 2022.