NATIONAL GARDEN BUREAU

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 National Garden Bureau. Guidelines for the pursuit of this commitment are set forth in this statement.

 

B. GUIDELINES FOR NATIONAL GARDEN BUREAU MEETINGS

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, approved by the Chairperson, and circulated to all who attended. They should be approved at the next meeting.

Proper Activities

1. Discussion of home garden industry-wide activities and concerns
2. Exchange of information on new developments in the home garden seed industry.

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

Membership is limited to individuals, firms, or corporations of good reputation who are engaged in the production and/or sale of vegetable and flower seed for home gardens and firms that manufacture packet containers for home garden seed. Corporate and firm members may designate one person to represent them 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 Organization.

 

D. STANDARDIZATION AND CERTIFICATION PROGRAMS

NGB 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 . NGB conducts only 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 Organization 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 . All statistics relate only to past transactions.
4. Availability . Data published by NGB are made available to all members and to nonmembers upon request and payment of reasonable charge where applicable.