Because Wells Fargo may bring together customers, suppliers, vendors, and possibly competitors, we must be mindful of the competition risks associated with the meeting. You should understand, recognize, and avoid situations where there may be even an appearance of a violation of applicable competition laws. This guidance is not intended to be or contain legal advice. Each attendee is advised to seek their own appropriate legal advice with respect to each individual firm’s compliance with applicable competition laws.

Wells Fargo anticompetitive behavior policy, along with federal and state law, prohibit the exchange, provision or receipt of commercially sensitive information between competitors. Commercially sensitive information includes, but is not limited to, current, recent, or future pricing or fee information, strategic plans (including intentions to focus on particular businesses or geographic areas), information regarding costs or profitability (including employee compensation), and proprietary technologies and trade secrets. In addition, such meetings should not be used for any other anticompetitive purposes such as group boycotts, price collusion, market sharing, or any other form of practice that might potentially restrict competition.

In order to facilitate compliance with Wells Fargo anticompetitive behavior policy and applicable competition laws, you agree to read, understand, and abide by the following Guidelines:

  1. Attendees must avoid discussing non-public competitively sensitive topics including the following: 
    1. Price/Margin
    2. Itemized Costs
    3. Sales volume 
    4. Sales strategy
    5. Business plans
    6. Market share 
    7. Business strategy
    8. Bidding strategy
    9. Specific Customers
  2. If such discussions nonetheless occur, attendees must immediately ask that such discussions cease. If the other party persists, end the conversation. 
  3. Attendees must:
    1. not discuss or refer to division of geographic markets, types of customers, or types of products.
    2. adhere to the topics in the meeting agenda.
    3. not disclose non-public, proprietary information.
    4. own their independent judgment with respect to its own business operations.
  4. Attendees may address any question relating to these Guidelines at Wholesale.antitrust.inquiries@wellsfargo.com.