Mantovani Navigation


Antitrust Policy


The antitrust laws seek to preserve a free competitive economy, based on the premise that free competition will yield the best allocation of economic resources, the lowest prices, the highest quality and the greatest material progress for the public welfare. As a general rule under the antitrust laws, competitors may not restrain competition through understandings and agreements as to the price, production, or the distribution of products and services. Competitors may not engage in any activity intended to opportunities of their customers, suppliers, or other competitors.

The antitrust laws are complex and often of unclear applicability. Unlawful agreements can be inferred from circumstantial evidence. Furthermore, penalties for violating the antitrust laws are severe. The guidelines, set forth below, are designed to avoid even the

appearance of questionable activity. Management and employees of Mantovani Navigation will not discuss the following:

1. Current or future prices.
2. What constitutes a “fair” profit level.
3. Possible increases or decreases in prices.
4. Standardization or stabilization of prices.
5. Pricing procedures.
6. Cash discounts.
7. Credit Terms.
8. Control of sales.
9. Allocation of markets or geographical division of markets.
10. Refusal to deal with a corporation or in dividual because of its or his pricing or distribution practices.
11. Freight allowances.
12. Whether or not the pricing practices of any industry member are unethical or constitute an unfair trade practice.

of Policy

Mantovani Navigation emphasizes its ongoing commitment to comply strictly and in all respects with the antitrust laws. It is the policy of Mantovani Navigation to be in compliance with all laws applicable to our activities.

Responsibility for
Antitrust Compliance

Mantovani navigation, our employees, and each business entity or person we deal with has an equivalent responsibility for antitrust compliance, and we must depend upon good judgment by all to avoid discussions and activities which could involve improper subject matter or improper procedures, or even an appearance of improper activity. All concerned have an important and individual responsibility for assuring antitrust compliance.

Compliance with the guidelines involves not only avoidance of antitrust violations, but avoidance of any behavior which might be considered improper. The guidelines are not inclusive of all applicable laws, but are intended to highlight and emphasize certain basic precautions designed to avoid antitrust problems. If there is any doubt, Mantovani Navigation will seek guidance from legal counsel.