Cartel Checklist
Use this checklist to spot and avoid cartel risks. Cartels are illegal agreements between competitors that restrict competition. If any of the āDonātsā occur ā stop immediately and report to Legal/Compliance.
ā Doās
- Keep discussions with competitors strictly limited to lawful topics (e.g., industry standards, public data).
- Have a clear agenda and circulate approved minutes for all competitor meetings.
- Leave and record your objection if a discussion turns to sensitive topics.
- Use āclean teamā protocols for competitively sensitive information in M&A due diligence.
- Report any suspicious approach to Legal/Compliance immediately.
ā Donāts
- Do not discuss or agree on current or future prices, discounts, or margins.
- Do not allocate markets, territories, or customers with competitors.
- Do not rig bids, rotate bids, or exchange bid information.
- Do not limit production, capacity, or output jointly with competitors.
- Do not exchange sensitive customer lists, costs, or strategic plans.
šØ Red Flags
- A competitor suggests ākeeping prices stableā or āavoiding a price war.ā
- An informal āgentlemenās agreementā or handshake deal is proposed.
- Requests to destroy notes, emails, or chat history after a meeting.
- Unexplained identical bids or prices across competitors.
āļø Educational checklist only ā always seek legal advice if in doubt.