Statement of Antitrust Policy

Through its seminars, technical conferences and other activities, RadTech brings together representatives of competitors in the UV/EB curing industry. Although the subject matter of RadTech activities is normally technical in nature, and although the purpose of these activities is principally educational and there is no intent to restrain competition in any manner, nevertheless the Board of Directors recognizes the possibility that the Association and its activities could be seen by some as an opportunity for anticompetitive conduct. For this reason, the Board has taken the opportunity, through this statement of policy, to make clear its unequivocal support for the policy of competition served by the antitrust laws and its uncompromising intent to comply strictly in all respects with those laws.

In addition to the Association’s firm commitment to the principle of competition served by the antitrust laws, the penalties which may be imposed upon both the Association and its individual and corporate members involved in any violation of the antitrust laws are so severe that good business judgment demands that every effort be made to avoid any such violation. Certain violations of the Sherman Act, such as price-fixing, are felony crimes for which individuals may be imprisoned for up to three (3) years or fined up to $100,000, or both, and corporations can be fined up to $1 million for each offense. In addition, treble damage claims by private parties (including class actions) for antitrust violations are extremely expensive to litigate and can result in judgments of a magnitude which could destroy the Association and seriously affect the financial interests of its members.

It shall be the responsibility of every member of RadTech to be guided by RadTech’s policy of strict compliance with the antitrust laws in all RadTech activities. It shall be the special responsibility of committee chairs and Association officers to ensure that this policy is known and adhered to in the course of activities pursued under their leadership.

To assist the RadTech staff and all its officers, directors and committee chairs in recognizing situations which may raise the appearance of an antitrust problem, the Board will as a matter of policy furnish to each of such persons the Association’s General Rules of Antitrust Compliance. The Association will also make available general legal advice when questions arise as to the manner in which the antitrust laws may apply to the activities of RadTech or any committee.

Antitrust compliance is the responsibility of every RadTech member. Any violation of the RadTech General Rules of Antitrust Compliance or this general policy will result in immediate suspension from membership in the Association and immediate removal from any Association office held by a member violating this policy.