The Confederation of Paper Industries Ltd (CPI) is subject to both UK and EU competition law. It is the general policy of CPI to comply with all laws applicable to its activities. This general policy includes strict compliance with UK and EU Competition Law.

The Competition Law Policy applies to all activities of CPI including its Sector Bodies, sectoral associations, Councils, committees, working groups, technical groups, and sub-groups.

Activities include the holding of meetings (both business meetings and social functions), representation at industry functions, the collection and dissemination of statistics, use of its website and the collection and distribution of other information related to the UK paper-related industry.

Compliance with this policy is the responsibility of each and every Member of CPI, all CPI staff, any person who acts on behalf of CPI and any person who participates in CPI activities.

MEMBER RESPONSIBILITY
In participating in a CPI activity, each Member and its representatives are required to:-

• co-operate fully with the CPI’s policy of compliance with competition law;
• familiarise themselves with the provisions of competition law;
• consider the competition law aspects of any CPI work they are involved in and if appropriate take relevant advice before voicing an opinion, exchanging information, committing to a course of action, taking a decision or reaching an agreement.

Members and their representatives must avoid any action, decision or agreement that might suggest the CPI is used as a vehicle to facilitate, or is a party to, any unlawful conduct under competition law.

CPI STAFF RESPONSIBILITY
Each member of staff, including temporary staff and consultants, is required to act in such a way as to avoid any breach of competition law.

Each member of staff is required to:

• adhere to the CPI Competition Law Policy;
• abide by the CPI’s Employee Obligations and Procedures on Competition Law;
• read the CPI’s Competition Law Guidance and familiarise themselves with the provisions of competition law;
• consider the competition law aspects of their work and if appropriate take relevant advice before committing to a course of action, taking a decision or reaching an agreement;
• share best practice on competition law issues;
  attend training sessions and read competition law update material as directed.

Staff interfacing with Members or responsible for the administration and/or management of any CPI activity, including committees, meetings etc, have additional responsibilities in respect of those activities with which they are involved. In particular they must ensure that the activity does not breach competition law.

Staff members’ concerns relating to competition law, including a breach or suspected breach, must be dealt with promptly and in accordance with the rules set out in the CPI’s Employee Obligations and Procedures on Competition Law.

CPI MANAGEMENT RESPONSIBILITY
Line managers are required to ensure that each of their members of staff, including temporary staff and consultants receives suitable guidance on competition law.

Departmental Heads and Staff Directors are required to consider, and if necessary put in place, any additional arrangements within their departments to ensure compliance with competition law. This includes arrangements for ensuring that any person acting on behalf of the CPI or participating in CPI activities e.g. seminar speakers abides by the CPI Competition Law Policy.

CPI Company Secretary is responsible for providing guidance, advice and training on competition law.

CPI Company Secretary will consider a compliance audit against its competition law policy and procedures every year. An audit will be undertaken on a periodic basis as agreed with the Director General to provide reasonable assurance that the policy and procedures are working effectively and to enable risk areas to be identified and addressed.

CPI Director General has overall responsibility for ensuring CPI compliance with UK and EU Competition Law.

CPI Council endorses this Competition Law policy and is committed to its incorporation throughout CPI.

CONFEDERATION OF PAPER INDUSTRIES LTD
issued november 2004