COMPETITION  LAW COMPLIANCE

We prohibit all forms of anti-competitive conduct with our competitors, including:

• price fixing and bid-rigging;
• fixing other competitive terms, such as margins or rebates;
• limiting production, or agreeing to reduce or limit production capacity;
• allocating markets, customers, suppliers or geographic territories; and
• boycotting any customer or supplier.

We have also established standards and procedures to ensure that the Compliance and Legal Functions conduct a prior legal review of competition law-sensitive activities.

Competition law risk assessments

All Businesses and Marketing are required to conduct periodic competition law risk assessments in consultation with the Compliance and Legal Functions. These follow our standard risk assessment process, including a process for identifying and regularly testing the effectiveness of the controls which are regarded as critical to manage competition law risk.

Competition law training and awareness

GEI Mekong identifies employees whose roles involve potential competition law risks. These employees receive regular training, developed and largely delivered by the Compliance Function. As with anti-corruption, competition law training may be delivered either online or in-person, and is focused on the needs of a business or function.

Steps are taken across GEI Mekong to regularly raise awareness of competition law issues. These include periodic messages from senior management emphasising the need for competition law compliance and the importance of working with integrity in our dealings with third parties including competitors.

Confidential reporting and investigations

Employees are supported and encouraged to report suspected competition issues via their manager or through the Legal and Compliance Functions. We also encourage people to report anti-competitive behaviour of competitors, suppliers or customers. The Compliance legal team manages investigations into all potential competition law issues.