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Responsible Sales and
Marketing Practices

Maintaining Accurate
Books and Records

Complying with
Competition Laws

Interacting
with Competitors

Interacting
With Customers

Interacting
with Competitors

You must exercise caution when interacting with competitors.

  • You must avoid cooperating, or even appearing to cooperate, with competitors.

  • You must never discuss any of the following topics with competitors without Legal’s consent:
    • Pricing or pricing policy, costs, marketing or strategic plans
    • Proprietary or confidential information
    • Technological improvements
    • Promotions we will conduct with customers
    • Division of customers, markets, territories or countries
    • Boycotts of certain customers, suppliers or competitors
    • Joint behavior toward customers

Even in the absence of formal contact, casual contact and exchange of information can create the appearance of an informal understanding between competitors. For this reason, P&G’s general rule is “No Contact with Competitors.” However, at times you may join trade associations and occasionally engage in various other activities with competitors, as long as you have permission from Legal.

  • Be extremely cautious when interacting with competitors at these events.

  • If a competitor attempts to discuss any of the prohibited topics with you in a trade association meeting, you must stop the conversation immediately, leave the meeting and report the incident to Legal.

Contact with suppliers who are also competitors is allowable, provided discussions and interactions are strictly limited to the purchase of the material, equipment, goods or services that P&G is buying, and provided Legal was aligned before contacting competition.

  • Purchases approval is required in line with Decision Authority policy, while Legal review is required for any allocation to a P&G Competitor which is not an arms-length transaction.

  • Arms-length transactions are those business interactions and transactions that can be considered ordinary, industry-standard purchases of raw materials or commodities at normal market conditions.