Compliance with the antitrust laws is a fundamental part of Southwestern's overall policy to comply fully with all laws applicable to its operations. This section of these Guidelines sets forth Southwestern's policies concerning antitrust compliance. When there is any doubt about any course of action that relates to these policies, Southwestern's Office of General Counsel or the Corporate Compliance Officer should be consulted.

The antitrust laws, both at the federal and state level, have a pervasive influence and effect on virtually all phases of Southwestern's operations. The severe consequences for companies and individuals who fail to comply with them make the antitrust laws especially important.

Simply stated, Southwestern's policy is to comply fully and completely with all antitrust laws applicable to our operations. Unfortunately, in many criminal prosecutions and civil lawsuits arising under the antitrust laws, circumstantial evidence is the basis upon which antitrust liability is found. Therefore, Southwestern wants to ensure that it avoids even the appearance of anti-competitive conduct.