Anti-Trust Policy

The GSM Association’s Anti-trust Legislation Compliance Policy Statement

It is the GSM Association’s Policy that all of its business dealings are carried out in full compliance with applicable anti-trust legislation. The GSM Association is fully committed to ensuring that HQ employees and consultants, and Members and Associate Members of the Association adhere to this Policy. In pursuit of this objective, the GSM Association has adopted a Compliance Manual that sets out procedures on compliance matters. Procedures for monitoring compliance have also been introduced. The Compliance Manual is available on the Association’s Infocentre.

All HQ employees, consultants and elected representatives/officials of the GSM Association are under an obligation to conduct all business dealings in accordance with any applicable anti-trust legislation. Each HQ employee, consultant (as appropriate) and elected official is required to read and familiarise him or herself thoroughly with the GSM Association’s Compliance Policy and follow the guidelines contained in the GSM Association’s Compliance Manual. This requirement applies in particular to the Association Chair, Deputy Chair, CEO, Members of the Executive Management Committee & Interim CEO Board and chairs and deputy chairs of Groups including working groups, regional groups, task forces, fora or any other GSM Association group.

Any HQ employee, consultant or elected official of the Association who by his/her conduct and/or business dealings intentionally or negligently breaches the GSM Association’s Anti-trust Compliance Policy will be subject to investigation and/or disciplinary action. In cases of a serious breach of the Compliance Policy, such behaviour will be deemed to constitute gross misconduct and may result in immediate suspension and/or dismissal either from employment with the Association or, as referred to above, from Membership or Associate Membership of the Association.

Members and Associate Members are already under a general obligation to conduct all activities connected with the GSM Association in accordance with any applicable anti-trust legislation. All Members and Associate Members are to ensure that any of their employees involved in GSM Association activities and all those carrying out activities within the Association on behalf of Members and Associate Members are fully informed about the GSM Association’s Compliance Policy as contained in this Manual. If the GSM Association becomes aware of any conduct by any employees or representatives of Members or Associate Members which may breach the Compliance Policy, the relevant Member(s) and/or Associate Member(s) will be advised. The GSM Association will work with the Member(s) and/or Associate Member(s) in question to investigate and rectify the situation. If this is not possible, or, in the unlikely event that a Member/Associate Member does not co-operate with the GSM Association in such circumstances, the Association may consider suspension or termination of membership.

The GSM Association undertakes to provide both general and specific training in order to ensure that HQ employees, consultants and others directly involved in the activities of the Association are fully informed as to the extent and the implications of the Compliance Policy and how it affects their business activities. Specialised training will be provided for the GSM Association’s CEO, Executive Directors, directors and elected officials.

The GSM Association undertakes to monitor compliance with its Compliance Policy and to take positive action if it appears that the policy is not fully effective. The responsibility for maintaining and monitoring the Association’s Compliance policy lies with the Association’s Legal HQ and ultimately with the Association’s Executive Management Committee & Interim CEO Board. The Compliance Policy will be reviewed regularly by Legal HQ to ensure that it is up-to-date with legislative changes and best practice policies. Where appropriate, external advisors may also be requested to perform audits of certain aspects of the compliance programme.