Peer Activities and Antitrust Guidelines

各种Gartner产品包含一个同伴ctivity component where clients with similar job roles within an IT organization, in the same or different industries, are convened by Gartner to exchange knowledge, impart insights and share best practices related to their information technology issues and challenges. These offerings include, but are not limited to, Research Board, Peer Connect, Global Peer Industry Forums, Events (Break-Out Sessions), EXP Academies and IT Executives. In connection with these peer activities Gartner often serves as moderator to facilitate discussion on topics that participants deem relevant. In some instances, Gartner may obtain certain benchmarking data and related company-specific data from the participants, which it may use in an aggregated and non-identifiable format in connection with the provision of its research services.

Participants in Gartner peer activities must be sensitive to discussion topics that might implicate antitrust / competition laws. To ensure that the participants understand and comply with these laws, Gartner is providing you with these Antitrust Guidelines, which constitute basic rules for interacting that are designed to avoid antitrust issues.We encourage you to review the Guidelines carefully and consult your own legal counsel if you have any questions.The Antitrust Guidelines, which are applicable globally, are incorporated into the meeting and/or online registration materials for all Gartner peer activity offerings. Along with the Antitrust Compliance Policy Statement attached as Exhibit I, the Antitrust Guidelines are intended to remind participants of their obligations in connection with their involvement in Gartner peer activities.

Antitrust compliance is the responsibility of every peer activity participant; as such we ask that you keep these Guidelines in mind when interacting with other participants at any Gartner peer activity.

Gartner assumesnoresponsibility for ensuring that peer activity discussions are appropriate and not in violation of any antitrust/competition laws. If you as a participant have any questions in this regard, you must consult your own legal counsel.

Basic Rule:

Agreements, whether written or verbal, or those that may signal or otherwise constitute tacit understandings that have the effect of lessening competition, could violate antitrust laws and expose participants of the Gartner peer activities to substantial legal liability.

Guidelines — Generally:

Do:	For Example:
Adhere to the meeting agenda and/or activity program	Various gatherings, including Research Board and Global Peer Industry Forums, have prepared agendas that are circulated in advance to all participants
Follow the Discussion Guidelines below
Discuss issues of general industry interest, but refrain from any discussions of commercially sensitive, strategic or confidential information in relation to participants' business Object to the discussion of improper subjects and take action to cease any improper discussions; if that fails, leave the meeting Seek guidance from your legal counsel if you have any questions or concerns	Permissible discussion topics include the effects of government legislation; historic, aggregated and statistical market data; and general industry experiences or opinions If the discussion turns to improper subjects such as model licensing terms for the competitors’ primary suppliers, you should object, take action to cease the improper discussion and if that fails, leave the meeting

Do:

For Example:

Adhere to the meeting agenda and/or activity program

Various gatherings, including Research Board and Global Peer Industry Forums, have prepared agendas that are circulated in advance to all participants

Follow the Discussion Guidelines below

Discuss issues of general industry interest, but refrain from any discussions of commercially sensitive, strategic or confidential information in relation to participants' business
Object to the discussion of improper subjects and take action to cease any improper discussions; if that fails, leave the meeting
Seek guidance from your legal counsel if you have any questions or concerns

Permissible discussion topics include the effects of government legislation; historic, aggregated and statistical market data; and general industry experiences or opinions

If the discussion turns to improper subjects such as model licensing terms for the competitors’ primary suppliers, you should object, take action to cease the improper discussion and if that fails, leave the meeting

Discussion Guidelines:

Do Not:
Engage in discussions regarding prices, fees or rates	For example: Discuss the methodology of setting prices Make any comments regarding your thoughts on past, current or future pricing Make an agreement about the prices that companies will charge their customers
参与相关讨论to production capacity	For example: Disclose any expansion or retraction plans Forecast future ability to meet market demand Agree to fix quality or quantities
Make any statements that could be interpreted as an invitation to coordinate behavior	Do not say: "Something needs to be done about low prices,” which can be interpreted as an invitation to raise prices" "Next week will be a good time to send out press releases regarding our capacity", which may be interpreted as an invitation to coordinate announcements to the market
Make any agreements allocating customers or geographic territories or markets	Do not agree to refrain from competing for certain customers or in certain countries in exchange for not having to face competition from another customer or in another country
Disclose any disaggregated, customer-specific information	For example: Disclose upcoming opportunities to win new customers Discuss prices charged to specific customers Disclose revenues attributable to specific customers
Discuss future plans regarding product lines	Do not disclose new product lines or research and development expenditures
Make any agreement regarding a joint action that may be taken against a customer, supplier, distributor, or competitor Attempt to prevent a supplier(s) from selling to your competitor(s)	Do not agree to: Refuse to deal with a particular customer Attempt to obtain more favorable terms from a supplier Refuse to enter into cross-supply agreements with a particular competitor
Discuss your company’s commercial strategy (which may be interpreted as an invitation to coordinate strategies or to otherwise enable a coordination of strategies) or agree on a joint strategy relating to the operation of your business	Do not discuss or agree: Internal costs Details of customers Sales and orders Market shares
Agree on uniform terms and conditions on which to deal with certain customers or suppliers that you have in common	If your company and another company both sell products or services to the same customer, do not Discuss the terms and conditions upon which you deal with that customer Agree not to supply that customer with products except on jointly agreed terms Agree on model licensing terms
Agree to forego entering into new lines of business that compete against the company of the participant with whom you are talking	If your company is intending to enter a new business, do not discuss with another company in that same business or industry the terms upon which you should or should not compete in that market.

Note: “Potential” competitors are subject to the same rules as “actual” competitors, and should take care to follow all of the Guidelines that are discussed above.

Exhibit I

同行活动/反垄断合规POLICY STATEMENT

As described in the Peer Activities Antitrust Guidelines, it is the obligation of all participants in any Gartner peer activity to comply at all times with all applicable antitrust laws, and to refrain from engaging in anticompetitive conduct. This includes, but is not limited to, the following:

Discussing or actively setting prices or production capacity.
Discussing or disclosing customer-specific information
Discussing or actively dividing or allocating markets or customers.
Discussing or actively engaging in boycotts or refusals to deal.
Discussing or taking joint action against a customer, supplier, distributor, or competitor.

Gartner assumesnoresponsibility for ensuring that discussions conducted during peer activities are appropriate and are not in violation of any antitrust laws. Participants who have any questions in this regard must consult their own legal counsel.