Antitrust Compliance Policy

The purpose of this Antitrust Compliance Policy is to ensure that all employees, officers, directors, and agents of Axion Biosystems understand and comply with antitrust laws. Adherence to these laws is critical to maintaining fair competition, protecting consumers, and safeguarding the reputation and success of our company.
This policy applies to all individuals acting on behalf of Axion Biosystems, including but not limited to employees, officers, directors, contractors, consultants, and agents.

Axion Biosystems is committed to full compliance with all applicable antitrust laws, including but not limited to the Sherman Act, the Clayton Act, and the Federal Trade Commission Act. These laws prohibit anticompetitive behavior, including price-fixing, bid-rigging, market allocation agreements, and monopolization.

The following conduct is strictly prohibited:

Price Fixing: Agreements, discussions, or understandings with competitors to fix, raise, lower, or stabilize prices.
Bid-Rigging: Collusion with competitors to manipulate the bidding process or to allocate customers or territories.
Market Allocation: Agreements with competitors to divide markets, customers, or territories.
Group Boycotts: Agreements with competitors to refuse to do business with certain suppliers, customers, or competitors.
Monopolization: Conduct intended to unlawfully acquire or maintain a monopoly position in a relevant market.

Employees are encouraged to report any potential violations of this policy or antitrust laws to HR or any member of the management team. Reports can be made anonymously, and Axion Biosystems will not tolerate retaliation against individuals who report violations in good faith.

Violations of this Antitrust Compliance Policy may result in disciplinary action, up to and including termination of employment. Additionally, individuals who engage in anticompetitive conduct may be subject to civil and criminal penalties, including fines and imprisonment.

This policy shall be periodically reviewed and updated as necessary to ensure compliance with changes in antitrust laws and regulations.