Competition Law Compliance Policy
This Competition Law Compliance Policy (“Policy”) sets out Al Ahram Beverages Company (ABC) policy of competing fairly in compliance with the Egyptian Competition Law No. 3 for 2005 (ECL). The Policy is designed to enhance and provide further guidance on how ABC conducts its daily business relations and its differentiation between the main legal and illegal competitive practices in accordance to the Competition Law and its assurance of the proper mechanisms to report to the management of ABC any illegal practice and provide the necessary support to ABC’s business partners.
- This Policy is intended to provide all ABC employees, Customers and Suppliers with a general understanding of ABC’s competition policy and will help to identify potential competition law issues and know when to seek advice. This isn’t a definitive document and should always be read and interpreted in conjunction with the Egyptian applicable laws
- The Egyptian Competition Law - ECL is designated to create a level playing field between companies so that they can compete effectively and fairly. Understanding the ECL also helps ABC to maintain a competitive edge.
- The ECL strictly prohibits the following:
- Anti-competitive agreements or practices
- Abuse of a dominant position
- acquisitions and joint ventures that undermine competitive framework in a business
- The ECL distinguishes so-called horizontal and vertical anti-competitive agreements or practices, elaborated as follows:
- “Horizontal” means agreements between competitors to divide markets by allocating customers, suppliers, territories or specific types of goods or services, as per Article 6 of the ECL.
- “Vertical” refers to agreements between companies operating at different levels of the supply and distribution chain, per Article 7 of the ECL.
- Below; without limitation, are the measures that all ABC employees are mandated to adhere to in compliance to the regulations of the ECL:
- Compete strongly and with integrity
- Treating all the customers and suppliers fairly.
- Actively promote ABC products.
- Using standard contracts that are in compliance to the Egyptian Laws.
- Not to engage in any agreement or in verbal discussions that may eliminate the distribution of any competitors products
- Not to apply tying conditions or obligations on the customers nor linking the supply of one product to the supply of a different product.
- Granting the discounts which are in compliance to the ECL and which shall not result in selling the products below their marginal cost.
- Not to impose any condition, obligation or incentives that may lead to exclusivity
- Not to apply different terms and conditions to customers without a legitimate, objective, commercial justification.
- Not to refrain customers from stocking competing products.
- Not to refuse to supply a customer, without objective justification.
- Not to prevent distributors from accepting orders from outside their territory/customer group.
- Appropriate Actions
If you have any concern regarding a possible violation of this policy, Speak Up. Raise any concern you have to one of the Trusted Representative, Global Business Conduct or online (http://speakup.heineken.com) or by phone through the Integrity Line No. : (02)-2510-0200.. All reporting is done confidentially and you can share your concerns anonymously.
Please note that the call will be answered in English Language and to continue your call in another language, please state your language to request an interpreter. It may take 1-3 minutes to arrange for an interpreter, during this time, please do not hang up
This Policy will be regularly reviewed and updated accordingly. Any changes to this Competition Law Compliance Policy will be posted on our Corporate Website (www.alahrambeverages.com).