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37

PLENCO CSR Initiative

V. Fair Business Practices

Plenco conducts business fairly and ethically. This applies to our relationships with our customers,

suppliers and contractors, legal and governmental authorities and the communities in which we operate.

Antitrust Commitment

Plenco adheres to the following antitrust

prohibitions

outlined by the United States Small Business

Administration (SBA), a United States government agency dedicated to preserving a healthy business

environment and marketplace in the United States:

Plenco maintains an active

Antitrust Compliance Program,

which is guided by a manual and educational

material made available to all Plenco employees. On an annual basis, Plenco’s corporate employees are

required to review the antitrust policies and guidelines and sign a certification document indicating their

understanding and compliance. Plenco’s whistleblower policy ensures that employees can feel secure in

reporting any observed improper activities to management as they relate to antitrust issues.

Conspiring to Fix Market Prices:

Discussing prices with competitors, even if it affects a

small marketplace, may be construed as a violation of

antitrust laws.

Price Discrimination:

Selling the same product to a large customer at a

lower price than to the customer’s smaller competitors,

unless due to identifiable cost savings, or to meet a

competitor’s price, is generally a violation of antitrust

laws.

Conspiring to Boycott:

Conversations with other businesses regarding the

potential boycott of another competitor or supplier may

violate antitrust laws.

Conspiring to Allocate Markets or Customers:

Agreements between competitors to divide up cus-

tomers, territories, or markets are illegal. This provision

applies even when the competitors do not dominate

the particular market or industry.

Monopolization:

Preserving a monopoly position through the acquisi-

tion of competitors, the exclusion of competitors to the

given market, or the control of market prices are all in

violation of antitrust laws.