Conduct with Customers, Suppliers and Competitors
Standard of Conduct
Avoid any conduct that violates, or might appear to violate, either the letter or spirit of an antitrust law.
All agents and distributors shall undergo appropriate background screening prior to doing business with the Company.
Do not enter into any agreement or understanding with any competitor regarding price.
Do not engage in or discuss with competitors or other business partners any prohibited activities that might be interpreted as an effort to improperly restrict or limit competition (such as pricing or sale terms).
Be cautious about indicators of collusion and avoid loose language.
We must avoid careless language in our electronic communications, memoranda, notes and public statements which might suggest anticompetitive practices. The following are examples of phrases that may suggest an invitation to a competitor:
Don’t claim future Tronox price or output actions are contingent on specific competitor responses. For example, phrases such as “I do not want to undercut a competitor” should be avoided.
Don’t suggest competitors or the industry should behave “rationally” and “appropriately” or should stop behaving “illogically”. A phrase such as the “industry lacks discipline” may be taken out of context and should be avoided.
Don’t discuss what industry price or output, or a competitor’s price or output, should be. A statement such as “the price increase is taking hold” may create an inference of collusion.
We manufacture and market products that can be handled safely. Tronox products are tested to ensure quality and safety standards are met. Our products are accompanied by clear and relevant safety information and appropriate warnings and instructions regarding any hazard that our products may pose to persons, property, or the environment.
It is important to make sure that you do not authorize the shipment of any product known to be defective, unsafe, or unsuited for its intended use.
Accepting Gifts from Vendors and Suppliers
Business gifts of significant value offered to you may be intended to improperly influence the selection of vendors or suppliers. Therefore, Tronox’s standards governing the acceptance of gifts from vendors or supplier companies or their agents mirror those related to giving gifts to our customers and prospective customers.