Anti-Trust Statement

American Seed Trade Association
STATEMENT OF ANTITRUST COMPLIANCE POLICY

A. POLICY

Commitment to full compliance with both the letter and the spirit of the antitrust laws is a fundamental commitment of the American Seed Trade Association. Guidelines for the pursuit of this commitment are set forth in this statement. In case of any question, the Association’s legal counsel should be consulted.

B. GUIDELINES FOR ASTA MEETINGS

Procedures

1. An agenda for all meetings should be prepared in advance, adopted by the group (with any changes) at the outset of a meeting, and carefully adhered to.
2. Minutes of all meetings should be prepared, cleared with the Association’s Washington office and circulated to all who attended. They should be approved at the next meeting.
3. Legal Counsel should review agendum and minutes and attend meetings involving antitrust-sensitive subjects.

Proper Activities

1. Discussion of industry-wide activities and concerns.
2. Exchange of information on new developments in the industry.
3. Promotion of markets for the industry as a whole.
4. Development of standards for noncompetitive items for voluntary use by industry members.
5. Development of common approach to legislative and regulatory matters.

Improper Activities

1. Discussion of pricing or promotional policies, other terms of sale, customer identity or geographic marketing areas.
2. Pressure on particular members or segments to adopt any particular program or policy.
3. Development of programs or policies designed to exclude some members of the industry.
4. Assisting members with problems peculiar to a single company.
5. Participation in unofficial or “rump” meetings on any subject which could not properly be discussed at an official meeting.

C. MEMBERSHIP

Active membership in this Association is open to any firm which is substantially engaged, in the U.S., Canada or Mexico, in the growing or selling of seed if it has an established place of business in such country and has established a satisfactory business reputation as more fully provided in the Bylaws. Continuation of membership is conditioned on continuing eligibility and payment of dues. Denial or exclusion from membership on the basis of any anti-competitive factor is not permitted by law and is contrary to the policy of the Association.

D. STANDARDIZATION AND CERTIFICATION PROGRAMS

The ASTA does not conduct any industrial standardization or certification programs. Any proposals for such programs would require thorough review of governing legal principles before implementation.

E. STATISTICS

1. Scope. The ASTA conducts only occasional or specialized statistical programs and any new program is subject to legal review under governing antitrust guidelines before implementation.
2. Confidentiality. In the collection of any statistics, collection is ordinarily handled by outside organizations under guidelines designed to preclude making data on any individual member known to any staff member or Association member. In those few cases where statistics are
   collected by staff, strict policies are established to ensure confidentiality of individual member statistics. In any case, published data are limited to aggregate data with the understanding that even aggregate data will not be published in cases where, because of the
   small number of reporting firms, the data of individual firms might be determined.
3. Nature of statistics. No statistics are collected relating to prices and all statistics relate only to past transactions./li>
4. Availability. Data published by ASTA are made available to all members and to nonmembers upon request and payment of reasonable charge where applicable.