Antitrust Compliance Guidelines
WCG Antitrust Compliance Guidelines Summary
(Click here to see the Complete Guidelines - draft)
June 8, 2010
Antitrust Considerations, Proactive Compliance Guidelines.
A detailed set of “Preliminary Antitrust Compliance Guidelines” for Wisconsin Central Group (“Group”) activities is separately provided. The Guidelines are more than a primer on antitrust law and legal obligations. The Guidelines are in the tradition of programs that promote highway safety by encouraging “defensive driving” practices. They Guidelines are designed to: (a) provide guidance on avoiding any perception of anti-competitive behavior; and (b) emphasize the pro-competitive effects and impacts of the Group's objectives and goals.
The Guidelines:
• Prohibit communication of “Sensitive Competitive Information” in ways that may have anti-competitive impacts;
• Provide a means for communication of information, including some types of “Sensitive Competitive Information” to advance objectives that are pro-competitive in their effect; and
• Provide mechanisms to assure transparency and accountability.
Application of the Antitrust Compliance Guidelines.
Wisconsin Central Group's Preliminary Antitrust Compliance Guidelines apply to organizational activities related to establishing the Group. The Guidelines will be updated to reflect the formal or informal structure adopted by the Group as circumstances warrant.
Noerr-Pennington Antitrust Immunity.
Most of the activity of the Group may, directly or indirectly, involve petitioning government or regulators. Such activities may also enjoy Noerr-Pennington antitrust immunity because of the level of interaction with government and common interest of various governmental entities in promoting the Group's goals. The Group will not engage in lobbying.