Adherence to the following antitrust guidance will help to ensure that all meetings within the framework of the British Bankers’ Association (“BBA”), such as advisory panels, working groups and liaison groups (the “BBA meetings”), do not give rise to any competition concerns. These antitrust guidelines complement existing compliance programmes of individual BBA members.
BBA members should not exchange competitively sensitive information The dialogue between BBA members should be limited to discussing concerns of general interest relating to the development of the market and should not involve any exchange of competitively sensitive information. In particular, the following information should not be exchanged:
current/recent (i.e. within the past six months) pricing information;
current/recent customer information;
future pricing intentions;
future customer strategy;
current/recent margin information; and
current input/supply costs.
All BBA Meetings should follow BBA standard procedure
In accordance with BBA standard procedure, written agendas and minutes should be prepared for all BBA meetings. In the context of less senior fora, it will be sufficient for the minutes to indicate only the topics discussed, what was agreed, and the action points arising (with comments/positions ascribed to particular individuals only by exception).
If an inappropriate topic is ever raised during a BBA meeting, the Chairman, whether the BBA executive or another panel member, should terminate the discussion and report the incident to the CEO and to ask for the contact details of the BBA’s lawyer.
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