Antitrust Policy

Fight against cartels – A cartel is an agreement, concerted practice or conspiracy among competitors to fix prices, submit collusive tenders, divide or share markets and, more generally, restrict competition. A cartel is regarded as the most egregious violation of Anti-Trust laws in most jurisdictions, which may lead to the imposition of significant fines as well as, in certain jurisdictions, criminal penalties.

Involvement in a cartel is unacceptable, The laws and regulations that sanction cartel conduct are in place in most jurisdictions. These laws and regulations are designed to promote free and fair competition and to protect consumers. Anti-Trust compliance programs are e to detect and prevent cartel. Orbit will take steps to ensure they are fully informed of applicable Anti-Trust laws and regulations in connection with cartel conduct and other Anti-Trust violations, and will monitor its employees and business partners to ensure full and continual compliance.

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Ethical Conduct – As a demonstration of our commitment, Orbit pledges to take a zero-tolerance approach to cartel conduct. At all times, Orbit will act professionally, fairly and with the utmost integrity in all business dealings and relationships. This will apply wherever they operate.

Legal compliance – Orbit will take steps to ensure they are fully informed of applicable Anti-Trust laws and regulations in connection with cartel conduct and other Anti-Trust violations and will monitor its employees and business partners to ensure full and continual compliance. Legal compliance ORBIT will ensure that it is aware of all applicable laws and regulations covering anti-competitive practices in all the jurisdictions in which it operates, and that it will obey and uphold those laws and regulations. Orbit will ensure that it is aware of, and is complying with, applicable laws and regulations in connection with cartels.

Code of conduct – Orbit undertakes to:

  1. Never make direct or indirect (via third parties including agents, suppliers or customers) contact with an actual or potential competitor or other third party, the object of which is to engage in cartel behavior.
  2. Never propose or reach an agreement, whether directly or indirectly, formally or informally, with actual or potential competitors, regarding any sensitive competition-related issues, including:
    1. Fixing prices
    2. Dividing or sharing markets, customers, or territories
    3. Rigging a competitive bidding process
  3. Report any indication or initiative of improper anticompetitive business conduct by an actual or potential competitor in accordance to your internal reporting procedure, including but not limited to, reporting to your legal department and/or to the relevant Anti-Trust authorities.
  4. Not to participate in a meeting of a trade association in which sensitive competition-related issues are discussed. If such subjects are raised during a meeting, employees must immediately ask for the discussion to end. If not, they must leave the meeting and ask for that to be noted in the minutes of the meeting.
  5. Ensure that all internal and external correspondence, including e-mails and texts, and documents, discussions and public statements do not contain any statements that might be misinterpreted by third parties or Anti-Trust authorities and courts in the context of a potential Anti-Trust investigation.
  6. Maintain independent judgment in pricing or selling of any products and/or services.
  7. Limit any information discussed during commercial negotiations, with or disclosed to competitors or other third parties, to that which is strictly necessary for completing or assessing the transaction.