Compliance Guidelines
Last update: 15.11.2022
Ensuring safety is the key to gaining acceptance of autonomous mobility on a broad scale. The Autonomous will start this critical discussion by gathering together the complete autonomous mobility ecosystem and facilitate a mutual exchange of ideas by offering various workshops on key topics (Safety & Security, Safety & AI, Safety & Architecture, Safety & Regulation), panel discussions, and keynote speeches.
At The Autonomous, we are committed to ensuring that all discussions take place in full compliance with the rules of competition law. In order to allow for an open exchange of ideas within the limits of the law, this Guideline sets out practicable rules for The Autonomous. Compliance with this Guideline is obligatory for all organisers and participants.
1. Permitted topics
Topics which may be covered in discussions, workshops and meetings organised by The Autonomous include:
- General technical and scientific developments relevant to The Autonomous mobility;
- Legislative proposals and / or regulatory measures and their impact on the autonomous mobility ecosystem;
- The political environment;
- Current economic developments and general developments in the industry (if publicly available);
- Exchange of freely available information e.g. economic data available online or in annual reports.
2. Non-permitted topics
Participants may not discuss, agree, share information on, or in any other way coordinate their behaviour regarding competitively sensitive issues, including:
- Current and future prices, including selling prices, purchasing prices, price components, price calculation, rebates, and intended changes in prices;
- Terms and conditions of supply and payment for contracts with third parties;
- Market sharing, including discussions on the division of sales territories or
customers (e.g. by size, product type, etc); - Co-ordination of bidding towards third parties, including information on
customers’ commercial expectations and the firm’s proposed response, as well as
information on proposed bids (whether a bid will be submitted, for which lots, etc); - Boycotts against certain companies, e.g. agreements not to work with certain customers or suppliers, or to exclude specific companies from discussions on the
establishment of a technical standard; - Information about business strategies and future market conduct, such as
planned investments or the commercial launch of new technologies or products (if not publicly available). In particular, agreements to delay a new technology or to fix the commercial terms of its introduction are prohibited; - Information on internal research & development projects. This comprises estimations about feasibility of specific technical solutions or the costs attached to the implementation of a specific solution.
- Any other information, which could lead to or may be interpreted as unlawful infringement of the applicable rules of competition law.
3. Measures to ensure compliance
In order to ensure compliance and to contribute to an open discussion, The Autonomous will implement the following measures:
- Attendance by legal counsel: All discussions and workshops may be attended by in-house or external legal counsel. Legal counsel may also break off or adjourn the discussion in case of doubts with regard to competition law compliance;
- Minutes: The moderator of each discussion or workshop may, jointly with a legal counsel, compile correct, complete and precise minutes of the discussions. Copies of these minutes will be provided to all participants. In case of errors, participants may request corrections of the minutes.
4. No reliance
The purpose of this Guideline is to briefly summarize the competition rules applying to discussions at The Autonomous. It however cannot address the full complexity of the applicable law, and does not constitute legal advice to participants and their respective firms as to their obligations under competition law.
At the Autonomous, we encourage participants to familiarize themselves with the rules of competition law. Should any participant have doubts as to the legality of any discussion in the course of The Autonomous, she / he may
- raise such doubts to the legal counsel attending the discussion. The legal counsel shall record any such request in the minutes;
- leave the meeting if the discussion continues without the participant’s doubts having been resolved. The legal counsel shall record the name of the participant as well as the exact time of the participant’s departure in the minutes.