Antitrust Compliance Policy Review

Antitrust Compliance Policy Review

Purpose

Review a company's antitrust compliance policy and supporting program materials against the conduct patterns its people actually face, producing a topic-coverage matrix, a jurisdiction-coverage matrix, gap assessments for training, reporting, enforcement, dawn-raid protocol, and document-creation guidance, and a drafting-suggestion list. Coverage is tested against the shared antitrust risk-indicator catalog so the policy is measured against the company's real risk environment, not a generic checklist. Everything is a draft for attorney review — the skill never attests compliance, approves the policy, or represents that it meets any jurisdiction's requirements.

Use When

• The GC asks for a gap review of the antitrust policy after an enforcement action, dawn raid, or internal-audit finding in the company or its industry.
• An acquisition or new market entry adds jurisdictions (e.g., EU or UK operations) the current policy was never written to cover.
• Compliance wants to know whether the policy actually addresses trade-association contacts, benchmarking, algorithmic pricing, or labor-market (no-poach / wage-fixing) conduct.
• The policy is due for a periodic refresh and counsel wants a topic-by-topic and jurisdiction-by-jurisdiction coverage map before redrafting.
• Sales or HR reports the policy is unusable for their teams, and role-specific audience-fit issues need to be documented.
• The board or a regulator asks what the compliance program covers, and counsel needs an inventory of training, reporting-channel, discipline, and dawn-raid provisions with gaps flagged.

Required Inputs

• Jurisdiction(s) the policy must cover — every country and, where relevant, state/province where the company operates and where compliance obligations apply, or [verify jurisdiction].
• Business scope covered — products, geographies, sales channels, customer segments, M&A activity, JV activity, IP licensing, distribution programs, employment / labor-market activity, public-procurement exposure.
• Topics in current policy and topics the user wants covered — competitor contacts; pricing and price-signaling; customer or territory allocation; output limitations; information exchange; trade-association participation; distribution restraints (RPM / MAP / territory / online); MFN / parity provisions; exclusivity, loyalty, and rebates; M&A clean teams and gun-jumping; dawn-raid protocol; document-creation guidance; algorithm and AI conduct; reporting and escalation; training; certifications; enforcement and discipline; labor-market conduct (no-poach / wage-fixing); standard-setting.
• Current policy text and supporting materials — the policy document(s), training materials, prior enforcement actions, internal audits, hotline data summaries (if user-supplied).
• Triggering events for this review — incident, M&A integration, regulatory development, periodic refresh, agency request, internal audit finding.
• Jurisdiction-specific obligations the policy must reflect — US Sherman / Clayton / FTC Act; EU Article 101 / 102; UK CA98 / DMCC; sector-specific regimes (e.g., communications, energy, financial services); merger-control regimes the company is subject to.
• Audience(s) for the policy — sales, marketing, procurement, R&D, executives, board, M&A team, HR. Mark unknowns unknown/not found/not provided/ambiguous.
• Documents and source anchors — policy file with section references; supporting materials.