Competition Compliance Policy


Wan Hai Lines Competition Compliance Policy

Feb. 2023

Wan Hai Lines is fully committed to enforce strict compliance with all the competition laws that are applicable to its operations. The main purpose of competition laws is to protect and promote free and fair competition. The competition laws prohibit agreements and arrangements among competitors that prevent, restrict or distort fair competition.

Employees at all levels are under an obligation to maintain strict compliance with Wan Hai Lines’ Competition Policy. No employee is allowed to violate the Policy in any way; failure to comply with the Policy will be subject to severe disciplinary action. The consequence of infringing competition laws can be very serious, both for Wan Hai Lines and for any employee whose conduct is the basis of the violation. Aside from the internal disciplinary action, the violation can result in significant fines and civil liability; it could also cause reputational damage and may lead to criminal risk.

Competition laws are complex and vary from country to country. Generally speaking, most domestic competition laws apply as long as the agreements and practices among competitors might have negative effect on the economy of the country. Those various laws generally address similar kinds of conduct and share common underlying concepts:
  • Price-fixing;
  • Capacity management;
  • Bid rigging;
  • Market allocation;
  • Group boycotts;

Aside from the above hard core activities, other activities might have potential anti-competitive risks. Judge whether the activity is in breach of competition laws from only certain facts is not possible, other backgrounds and factors should be considered. The fundamental principle is all decisions should be made independently and not on the basis of consensus or agreements among/between competitors. Any employee has doubt as to the legality of activities/agreements with competitors, seek advice from Legal Compliance Unit.

Employees are required to report promptly to the Legal Compliance Unit or supervisors any misconduct with competition implications of which they become aware. It is the responsibility of each employee to understand and comply with the Policy. If situations arise in which an employee has concerns about the competition implications of certain conduct, employees are encouraged to contact the Legal Compliance Unit by making a call to +886 2 2567 7961 ext.6363 or address your questions at competition@wanhai.com for guidance.

Wan Hai Lines takes competition compliance very seriously. Complying with applicable competition law is always the first consideration when doing business. Make sure all employees aware of competition laws is one of the ways to achieve it. Wai Hai Lines provides a Competition Compliance Manual as attached, which contains basic guidance of competition compliance and will help employees to identify potential competition issues and know when to seek advice.