THE ANTITRUST COMPLIANCE POLICY OF THE EBMA

The following rules are applicable to all Educational Book and Media Association (“EBMA”) activities and must be observed in all situations and under all circumstances, without exception or qualification other than as noted below.

1. Neither the EBMA nor any committee, conference or activity of the EBMA shall be used for the purpose of bringing about, or attempting to bring about, any understanding or agreement, whether written or oral, formal or informal, expressed or implied, among competitors with regard to prices, terms, or conditions of sale, discounts, distribution, volume of sales, territories or customers.

2. No EBMA activity or communication shall include discussions of or action concerning prices or pricing methods, quotas or other limitations on sales, or involve allocation of territories or markets or customers in any way.

3. No EBMA committee shall undertake any activity which involves exchange or collection and dissemination among competitors of any information regarding prices, pricing methods, cost, or of sales or distribution or individual company statistics of any kind, without first obtaining the advice of legal counsel provided by the Association, as to those proper and lawful methods by which these activities may be pursued.

4. No EBMA activity or communication shall include any discussion or action which might be construed as an attempt to prevent any person or business entity from gaining access to any market or to any customer for goods or services, or to prevent or boycott any business entity from obtaining a supply of goods or otherwise purchasing goods or services freely in the market.

5. No EBMA activity or communication shall include any discussion or action which might be construed as an agreement or understanding to refrain from purchasing any goods, materials, equipment, services or other supplies from any supplier.

6. Neither the EBMA nor any committee thereof, shall make any effort to bring about the standardization of any product or method of manufacture or certification of any product or program for the purpose of preventing the manufacture or sale of any product not conforming to a specified standard or which would tend to have the overall effect of either lessening competition or resulting in a degree of price stabilization.

7. No person or company meeting the requirements for EBMA membership shall be unreasonably excluded from EBMA membership or participation in any EBMA activity where such exclusion may impair such person’s or company’s ability to compete effectively in the book and/or media distribution industries.

8. In conducting EBMA meetings, the President, or their proxy, shall prepare and follow a formal agenda. Minutes of each meeting shall be distributed to all directors. Approval of the minutes shall be obtained at the next meeting.

9. Association speakers and authors shall be informed of the need to comply with the Association’s antitrust policy in the preparation and presentation of their papers.

10. In informal or social discussions at the site of an EBMA meeting, which are beyond the control of its officers, all representatives are expected to observe the same standards of personal conduct required of the Association in its compliance with these antitrust guidelines. In addition, a copy of these General Rules of Antitrust Compliance will be included in the EBMA Membership Directory and material for the Annual Meeting.