2022 Code of Ethics | Page 34

GRATUITIES , GIFTS & TIPS
BBNC is committed to fostering quality relationships with suppliers , customers , our community , and each other . To ensure that our relationships are honorable and reputable , the following guidelines should be used in giving and accepting gifts , tips and gratuities .
BBNC employees may provide or accept meals , refreshments , entertainment , and other business courtesies of reasonable value to or from non-government persons in support of business activities , provided :
The practice does not violate any law , regulation , or standard of conduct of the recipient ’ s organization ; and
The business courtesy must be consistent with marketplace practices , infrequent in nature , and not lavish or extravagant . Use common sense and good judgment in this area .
ANTITRUST & COMPETITION
BBNC complies with all applicable state and federal antitrust laws . Federal antitrust laws protect consumers from illegal competitive actions such as price fixing and division of markets . Non-compliance with applicable laws can result in civil violations up to $ 100 million and criminal penalties may include jail time .
Antitrust laws prohibit employees from entering into any kind of agreement or understanding ( even oral or informal ) with a competitor on :
Prices ; Territories ; Limitations on products or services ; Market share ;
The wages or other benefits paid to employees , or regarding which workers each company will or will not hire ;
Any action , which affects , limits , or restricts competition .
Unlawful agreements do not require a written document signed by the parties involved . If competitors make a conscious commitment to a common course of anticompetitive action , they could be in violation of antitrust laws .
BBNC is free to price our products and services as we choose , but in doing so , we may not maintain or expand our market share through illegal or restrictive practices .
Your Responsibilities
NEVER discuss or agree with competitors to fix prices or divide markets .
NEVER attend meetings or social gatherings with competitors where prices , costs , sales , profits , market shares , or other competitive subjects are discussed .
Be careful when speaking with competitors . Avoid the appearance of wrongdoing .
DO NOT enter into any understanding with a competitor that restricts either parties ’ discretion to manufacture or sell any products or provide any service , or which limits selling to , or buying from , a third party .
DO NOT share competitively sensitive information such as prices , wages , or costs with a competitor .
BBNC Code of Ethics | Ethics Hotline : 1.866.513.7078 | August 5 , 2022 | info . bbnc . net 31