International Business Practices

International Business Practices

We compete with openness, honesty and fairness, complying with both the letter and the intent of the laws applicable to our business operations.

Competition laws

Competition laws prohibit practices that restrain trade or restrict free and fair competition. All countries in which our Company operates, as well as the European Union, have enacted competition laws. These laws apply to us as both a supplier and a buyer of goods and services. Although competition laws differ from country to country, some of the most common practices that are or may be prohibited are described below.

  • Agreements or understandings with a competitor to fix, raise, peg, stabilize or even lower prices, or to eliminate or reduce price competition, are unlawful. Even an informal understanding or mutual expectation that two competitors could achieve a common purpose might be found to constitute an illegal agreement.
  • Agreements or understandings with a competitor to allocate or apportion customers, groups of customers, lines of business, products or geographic areas are unlawful. Here again, even an informal, tacit or unwritten understanding could be found to constitute an illegal agreement.
  • Certain agreements or understandings with suppliers or customers which involve exclusivity or other restrictive arrangements may be unlawful.

Competition laws are complex and the provisions in the Code are not intended to serve as a complete and definitive statement on every aspect of competition laws. Who we do business with and on what terms generally should not be discussed with persons outside our Company. Breaching competition laws can result in severe penalties, including criminal action against our Company or any individual involved.

Find out more Contact your Compliance Officer or Legal Department.

Anti-Corruption laws

As with competition laws, the countries in which we operate have enacted anti-corruption laws that apply to our business activities. Many of these laws have extraterritorial application, meaning that the laws of one country can apply to our Company’s activities outside of that country. Moreover, several international organizations have adopted anti-corruption rules and requirements that apply to our Company’s global operations.

A common theme applicable to virtually all anti-corruption laws is that individuals and entities are prohibited from offering or giving anything of value to any governmental or other public official with the intention of obtaining the official’s assistance in business matters. The prohibition will apply to any type of payment or gift, regardless of amount or value, if made for the purpose of gaining a business advantage of any kind, and covers payments made indirectly, through a third party, or to a family member or friend of the public official.

Moreover, the definition of “public official” is extremely broad and includes all officials, employees, agents and representatives of any governmental department, agency or branch (including advisors to such agencies and branches), directors, officers and employees of State-owned or controlled companies (including their consultants, advisors, agents and other representatives), political parties, party officials and candidates for office, and officials and employees of public international organizations such as the European Union or the United Nations (including their consultants, advisors, agents and other representatives).

The rules in some jurisdictions also prohibit offering or providing any financial or other advantage to persons in private business who are in a position of trust or responsibility.

Anti-Corruption rules and regulations are comprehensive and complex. Additional guidance is included in our Anti-Corruption Policy and in this Code under “Gifts and Entertainment – Public Officials”. You are required to read, understand and comply with the Anti-Corruption Policy.

Allegations of corruption can do serious damage to our business and reputation. It is essential that we comply with all applicable Anti-Corruption laws in the conduct of our business. Any director, officer or employee who is found to be violating applicable Anti-Corruption laws will be subject to disciplinary action which may ultimately lead to dismissal and, if appropriate, criminal proceedings.

Find out more Contact your Compliance Officer or Legal Department. The Anti-Corruption Policy can be found on your local intranet.

Laws affecting international trade and transactions

Most countries have adopted laws regulating international business relationships. Some of these laws restrict the export of goods, technologies and software to specific users or locations. Exports are not limited to traditional shipping methods. An export can be made electronically, through discussions and by visual inspection. Other laws prohibit business dealings with specific sanctioned countries, entities or individuals. The combination of export control laws and sanctions adopted by individual countries, some of which apply to our Company’s activities outside of that country, and through international treaties is complex. Among those who may be affected by these laws in performing their employment duties are persons involved with (i) mergers, acquisitions and investments in companies and businesses, (ii) procurement of equipment, software or technologies (including imports, exports, re-exports, and distribution of equipment, software or technologies), and (iii) provision of communications (or other high tech) equipment or software across national borders. The foregoing list is illustrative, not exhaustive. If you are involved in any of the foregoing types of activities, you should seek guidance from your Compliance Officer or Legal Department or a member of the Liberty Global Group Legal Department on how these laws affect your business activities.

Find out more Contact your Compliance Officer or Legal Department.