Antitrust Policy

Antitrust Policy Statement for Members of the Revenue Analytics Collaborative

It is the policy of Revenue Analytics Collaborative (RAC) and its members and participants to comply fully with both the letter and spirit of all federal and state antitrust laws.  The purpose of the meetings of RAC is to engage in a pro-competitive exchange of information and ideas concerning best practices and challenges in the life sciences industry, and to share commercial, government and gross-to-net expertise.

The antitrust laws exist to promote and maintain full and fair competition.  In addition to being the law of the United States, it is sound policy to comply with both the spirit and the letter of the federal and state antitrust laws because antitrust violations can have serious consequences for companies and their employees.  Defending an antitrust investigation or case is expensive, time-consuming, and disruptive to normal business operations.  A finding of an antitrust violation can result in criminal fines, incarceration, civil penalties, treble damages, and injunctive relief that may impact future business activity. Therefore, all members of RAC are reminded that all discussions are intended to and will be conducted in compliance with the antitrust laws. 

Specifically, it is important to avoid any formal or informal exchange of information that could facilitate anticompetitive cooperation among competitors.  Members or participants must not engage in any discussions regarding any information or topic that could be considered competitively sensitive, confidential, proprietary, or a trade secret.  Such information or topics that members or participants must avoid include, but are not limited to: the prices at which they currently purchase or sell, or intend to purchase or sell, products to or from individual third parties; the quantities they intend to produce or purchase; the specific customers or vendors with whom they do business; the terms or conditions of sale, profits, or profit margins; market conditions for any particular commodity or volume of material; the specific availability of supply or customer-specific demand for quantities of material; or the markets in which they purchase or sell products.

This Antitrust Policy Statement has been prepared in order to set forth RAC’s antitrust policy only, and is not offered, and should not be construed, as legal advice.