The ISCM Policy has been, and continues to be, to require full compliance with the antitrust and competition laws, and the avoidance of even the appearance of impropriety under those laws, in connection with ISCM activities anywhere in the world. This Policy applies to all members of the ISCM. The following three rules are the foundation of the ISCM’s Policy and integral to its members’ conduct:
1. ISCM MEMBERS MUST UNILATERALLY SET THEIR OWN BUSINESS TERMS.
ISCM members must never agree with each other on any term of trade or business strategy concerning products that members currently offer. Such terms include prices or premiums, volume of business, underwriting terms or standards, brokerage commissions or other fees, market share, customers, types of business written or not written, coverage terms and territories.
2. DO NOT DISCUSS COMPETITIVELY SENSITIVE MATTERS. Members should not discuss with each other competitively sensitive issues concerning products currently or that may be offered, such as pricing or premiums, underwriting or coverage terms and standards, loss experience, rate-related information, reserves, IBNR, volume of business, customers, or specific elements of profitability. If such information is not otherwise publicly available or properly disseminated by the ISCM itself, it should not be discussed.
3. ASK BEFORE YOU ACT.
Consultation with counsel can save untold time and money and can avoid embarrassment to the ISCM and its members.