CODE OF CONDUCT

Code of Conduct of Foro Madrid Carga Aérea, regarding competition issues.

The Madrid Air Cargo Forum, hereinafter "Foro MADCARGO" is an independent and non-profit association of professionals of the Madrid Air Cargo Community. The Association is open to professionals of the companies involved in the different segments of the air logistics chain from the shipper to the final receiver of the goods, including exporters, importers, airlines, freight forwarders and logistics operators, integrators, handling operators, public administrations, infrastructure managers, carriers, etc. The Forum also includes professionals interested in Madrid Air Cargo from other sectors such as the academic and scientific world, the media, etc.

Foro MADCARGO was founded in 2010 to support the development of air cargo in Madrid, promoting knowledge and good practices in the airport logistics chain and developing strategies that contribute to improving Madrid's competitive position on the global air cargo map. To promote its projects, Foro MADCARGO has been associated since February 2016 to UNO, Logistics and Transport Organization, actively participating and developing activities in its Air Cargo and Airport Activities Commission.

Foro MADCARGO has adopted this code of conduct in relation to competition issues, hereinafter referred to as "Code" to clarify any issues in this regard and to establish the conduct to be followed by all its members in relation to the activities of Foro MADCARGO; events, meetings and documentation. This Code is not exhaustive and serves only as a general guide complementary to what is indicated in the Bylaws of the Association.

About Foro MADCARGO - Foro MADCARGO has the following mission and structure Mission - To be a "Meeting Point" of professionals from the different air cargo sectors for:

  • To promote the activity of air freight transport, with origin and/or destination Madrid airport.
  • Define air freight strategies to improve Madrid's competitive position.
  • To face the challenges arising from the development of Air Cargo through the search for common positions of the professionals of the different activities involved in the Air Cargo Community of Madrid.
  • To transmit before the Public Administration Bodies with responsibilities in the sector, the interests shared by the Air Cargo Community of Madrid, in a responsible and proactive way, so that the infrastructures, services and regulatory developments that allow to solve those inefficiencies that hinder the competitiveness of the sector are considered and planned.
  • To convince institutions and public opinion of the strategic importance for economic growth and job creation of Madrid assuming the development of Air Cargo with the ambition of leadership on a European scale, creating a social support that is currently non-existent.

Structure - The structure of the MADCARGO Forum is organized on three levels:

  • The General Assembly, as the highest representative body of all the members of the MADCARGO Forum, with the main objective of making decisions to reach the necessary agreements to ensure the fulfillment of the objectives and the continuity of the MADCARGO Forum.
  • The Board of Directors is the management body that, following the guidelines of the General Assembly, directs, plans and coordinates activities. It also reviews and updates the strategy and policies of the MADCARGO Forum to fulfill its mission.
  • Working Groups, created by the Board of Directors to analyze and deal with specific issues or projects.

Benefits of the MADCARGO Forum for the Madrid Air Cargo Community - The MADCARGO Forum promotes a competitive environment and offers the following advantages to its members and the Madrid Air Cargo community:

  • Organization of events and meetings for the exchange of knowledge on the air cargo situation in Madrid and best practices worldwide.
  • Independent research and reporting related to Air Cargo.
  • Activities for the development of knowledge and recognition by society as a whole of the importance of Air Cargo and its professionals.
  • Information and collaboration with the different public administrations.

Objectives of the Code in relation to competition issues The Madrid Air Cargo Forum declares not to aspire to provide any platform and not to support any discussion on issues that could lead to anti-competitive actions. All members of the MADCARGO Forum develop their professional relationships and discuss issues related to air cargo and the international logistics chain, as well as other policies that may promote a pro-competitive environment for the continued development of air cargo.

The MADCARGO Forum will discourage any conduct that is not appropriate to free competition and that may be illegal under EU and other anti-competition laws. MADCARGO Forum members will not take or facilitate any action relating to: Price fixing, customer allocation, boycott groups, market and territory allocation. This list is for illustrative purposes only and is in no way meant to be exhaustive.

The MADCARGO Forum shall not be used as a channel for anti-competitive actions or facilitator of exchange of competitively sensitive information such as: information on prices, customers, production data, competitive strategies and plans, or any other sensitive information that is not in the public domain about competition.

Whoever violates this Code at MADCARGO Forum meetings will be called to order in accordance with the precautions contained in the Code and removed from the meeting if the practitioner persists in continuing the discussion or disseminating the information.

All members of the MADCARGO Forum assume that each member is responsible for complying with this Code at all times. If any member of the MADCARGO Forum has any doubts or suspicions about any member who may be violating the Code, he/she should inform the MADCARGO Forum Board of Directors who will bring it to the attention of the General Assembly for appropriate action.

Actions to prevent antitrust violations

At the beginning of each MADCARGO Forum project or activity involving any of its members, the Board of Directors shall ensure that all participants are made aware of this Code and its implementation, as well as the fact that all initiatives led by the MADCARGO Forum need to comply with it. The Board will review each project to ensure that it is consistent with this Code.

2. The MADCARGO Forum will ensure that each meeting is convened by an agenda distributed in a timely manner to all members so that they are assured that the meeting is in line with the Code and with anti-competition and anti-trust laws.

3. The Chairperson of each MADCARGO Forum meeting shall advise of the precautions contained in the Code at the beginning of each meeting.

4. At the end of each meeting, minutes will be issued with a comprehensive summary of the meeting to be circulated to the meeting participants.

This Code will be published on the MADCARGO Forum website and distributed to all its members.

Madrid, November 10, 2016

Signed by the Board of Directors.

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