Anti-Trust Policy

ARCA INTERNATIONAL INC. is committed to the Privacy Principles covering all Personal Data received by ARCA INTERNATIONAL INC. in the U.S. from European Union member countries and Switzerland in reliance on the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).

Purpose

This Anti-Trust Management Policy (“Policy”) establishes a framework for ARCA International (“ARCA”) to comply with all applicable anti-trust laws and regulations. ARCA is committed to conducting its business with integrity and fairness, and this Policy is designed to ensure that we do not engage in any anti-competitive practices that could harm consumers or competitors.

Scope

This Policy applies to all ARCA employees, directors, officers, agents, and contractors, as well as any affiliated companies.

Policy Statement

ARCA is committed to:

Complying with all applicable anti-trust laws and regulations.
Avoiding anti-competitive agreements, such as price fixing, market allocation, and customer or supplier boycotts.
Avoiding unfair competition, such as predatory pricing or exclusive dealing arrangements.
Maintaining independent pricing and business decisions.
Avoiding engaging in any actions that could harm competition or consumer welfare.

Responsibilities

Senior Management: Senior management is responsible for promoting and enforcing this Policy. They must provide adequate resources and training to ensure that all employees understand their responsibilities under this Policy.
Legal Department: The legal department is responsible for interpreting and applying anti-trust laws and regulations to ARCA’s business practices. They should be consulted on any issue that may raise anti-trust concerns.
Employees: All employees have a responsibility to comply with this Policy and to report any suspected violations. Employees should be aware of the potential anti-trust risks associated with their job duties and should seek guidance from the legal department if they are unsure about any particular issue.

Procedures

Compliance Training: All employees will receive training on anti-trust laws and regulations. The training will be tailored to the specific job duties of each employee and will be updated regularly to reflect changes in the law.
Review of Agreements: All agreements with other companies will be reviewed by the legal department to ensure that they comply with anti-trust laws.
Monitoring and Reporting: ARCA will monitor its business practices to identify and address any potential anti-trust concerns. Employees are encouraged to report any suspected violations to the legal department.
Investigation and Remediation: If a violation of this Policy is discovered, ARCA will take appropriate action to investigate the violation and remediate any harm caused. This may include disciplinary action against employees, termination of contracts, or changes to business practices.

Recordkeeping

ARCA will maintain records of all anti-trust compliance activities, including training materials, legal reviews of agreements, and investigations of suspected violations. These records will be kept for a minimum of seven years.

Revisions

This Policy will be reviewed and updated periodically to reflect changes in anti-trust laws and regulations, as well as changes in ARCA’s business operations.