Never make direct or indirect (via third parties including agents, suppliers or customers) contact with an actual or potential competitor or other third parties, the object of which is to engage in cartel behaviour.
Never propose or reach an agreement, whether directly or indirectly, formally or informally, with actual or potential competitors, regarding any sensitive competition-related issues, including:

• Fixing prices
• Dividing or sharing markets, customers or territories
• Rigging a competitive bidding process.

Report any indication or initiative of improper anticompetitive business conduct by an actual or potential competitor in accordance to our internal reporting procedure, including but not limited to, reporting to the legal department and/or to the relevant Anti-Trust authorities.

Not to participate in a meeting of a trade association in which sensitive competition-related issues are discussed. If such subjects are raised during a meeting, employees of Star must immediately ask for the discussion to end. If not, they must leave the meeting and ask for that to be noted in the minutes of the meeting.

Ensure that all internal and external correspondence, including e-mails and texts, and documents, discussions and public statements do not contain any statements that might be misinterpreted by third parties or Anti-Trust authorities and courts in the context of a potential Anti-Trust investigation.

Maintain independent judgment in pricing or selling of any products and/or services.

Limit any information discussed during commercial negotiations, with or disclosed to competitors or other third parties, to that which is strictly necessary for completing or assessing the transaction.

As a demonstration of its commitment, Star Worldwide Group pledges to take a zero-tolerance approach to cartel conduct. At all times, Star will act professionally, fairly and with the utmost integrity in all business dealings and relationships. This will apply wherever we operate.

Star Worldwide Group commit to legal and ethical behaviour, and to refrain from engaging in any business that will harm the interests of Star, FIDI, other affiliates, clients, or the industry. We will take steps to ensure we are fully informed of applicable Anti-Trust laws and regulations in connection with cartel conduct and other Anti-Trust violations and will monitor our employees and business partners to ensure full and continual compliance.

In case of any violation, any person shall immediately notify Board of Directors and/or Managing Director of Star Worldwide Group. If an employee receives any inquiry from any governmental agency or from any legal firm regarding any alleged antitrust violation, please notify the above-mentioned person(s) immediately.

Issue date – 28 April 2021
Last Reviewed on  – October 2023
Next Review on – April 2024