CODE OF CONDUCT

EURALARM, the European Trade Association for the electronic Fire & Security Industry, states that EURALARM

• considers it mandatory that its activities are at all times carried out in accordance with the applicable law, especially the competition law (e.g. Art. 81 of the Treaty of Rome) but also laws on fraud and corruption
• supports that business must be conducted in an atmosphere of free competition, i.e. on the basis of price, technology and quality
• recognises that legislation quoted above intends to stimulate free competition and therefore this legislation has its full support
• confirms this position by issuing a EURALARM Code of Conduct that is binding to all its members.
• with this code, endeavours to create trust in the integrity of the sector, among all parties and institutions involved.

This EURALARM Code of Conduct provides clear rules to it’s members, thus reducing the risk of improper conduct and consequently of fines being imposed. Violation of this Code of Conduct will result in EURALARM imposing sanctions.

With simultaneous use of the EURALARM code and the member company/association code the EURALARM’ code will only prevail when there it is a matter of an action, discussion or decision originating from EURALARM.

I. CONSULTATION AND DECISION-TAKING WITHIN EURALARM

The following rules shall at all times be respected within EURALARM:

A. PROCEDURES

• Meetings of a body, committee, working group or other forms of cooperation within the Association will only take place after they have been convened in writing. The notice convening the meeting shall also include the agenda for the meeting.
• Minutes will be kept of each meeting as referred to in 1. above; these will be sent to all members invited to the meeting. The minutes will also be available to the Board of the Association for their information.
• During the meetings it may not be decided to discuss certain topics that are subject to the condition that they will not be recorded in the minutes. If such condition is stipulated the chairman of the meeting may refuse to proceed to discuss the topic in question.
• During a meeting if market-related topics are discussed and if there are doubts about such sensitivities, the chairman should suspend the discussion on that subject until the advice of an expert in the field of competition law is obtained.

B. PROHIBITED TOPICS

The following topics are definitely prohibited within and on behalf of EURALARM:

• information or arrangements about prices, price components, rebates, pricing strategy and calculation, and intended change in prices,
• terms and conditions for supply and payment, relating to contracts with third parties,
• information about business strategies and future market conduct,
• detailed information about profits, profit margin, market shares, and intended investments, as far as this information is not publicly available,
• co-ordination of bidding towards third parties, regional or personal division of markets or sources, express or tacit agreement about boycotting certain companies or cutting-off the supply or purchase against a certain company.

C. TOPICS THAT MIGHT PRESENT A PROBLEM

The following topics might, under certain circumstances, present a problem from a competition law point of view. This means that these topics must at all times be discussed, within the context of the trade organisation, in proper consultation with an expert in the field of competition law:

• Schemes for recognition/membership criteria. For as long as recognition or membership of the trade organisation does not play a decisive part for the potential customer when choosing a product or service, there are no objections to this from a competition law point of view. As soon as the customer does find this important, however, these schemes must satisfy specific criteria
• The secretariat is allowed, in principle, to collect commercial information about individual companies and the trade organisation may make this information available to the members in an aggregated manner; however, this may sometimes lead to problems. It must in any event be guaranteed that individual members cannot take note of information about other members

D. Position Papers and Press Releases

EURALARM ensures that no position paper or press release contains a wording that, intentionally or unintentionally, could suggest an arrangement, an uniform conduct or a recommendation by EURALARM or by member companies that indicates above wording

Allowed wording is:

• Objective reporting about the market’s situation and development,
• Presenting alternative solutions without preferring a certain one.

II. STANDARDS OF CONDUCT; INDIVIDUAL MARKET CONDUCT OF MEMBERS

In order to protect the good name of EURALARM it is important that the individual members respect the following rules in their market conduct:

• The members shall refrain from any conduct that might jeopardize the professional integrity of EURALARM.
• The members shall refrain from any form of bribery of potential customers, governments and other third parties in order to gain commercial or financial advantage.

III. EXECUTION/ENFORCEMENT

EURALARM will implement this Code of Conduct by informing all Euralarm members about this regulation with binding rules for members and their representatives and will stipulate that violation or non-observance may result in immediate termination of membership. Other forms of sanction include warnings, reprimands and suspensions.

This Euralarm Code of Conduct has been approved and accepted by the Euralarm Board members unanimously at their meeting on September 5th, 2012 in Paris.