EPP Code of Ethics and Professional Conduct
Upon founding the EPP it was determined that there was a need for a professional code of conduct. This first Code of Conduct has first been written in 2007, with special thanks to Mr. Rein Wesseling from the international law firm Stibbe and the NMa (The Netherlands). In 2011 this code has been reviewed and today is has been integrated it into our current EPP Code of Ethics and Professional Conduct.
Vision and purpose
1.1 Why a Code of Ethics and Professional Conduct
- Both the EPP and participants win by ensuring a correct platform of discussion and learning in order to develop both their individual skills and the pricing maturity in their organisations;
- The EPP wants to ensure that all participants are committed to adherence to the applicable laws and regulations, in particular the competition laws, during all (on- and offline) EPP activities and events.
- The pricing and profit optimisation management profession is shaped by the collective conduct of individual practitioners;
- The EPP beliefs that for the growth of the pricing profession in Europe, emphasis on acting and behaving ethically can advance the profession, both individually and collectively;
- The EPP needs clear values and norms for making wise decisions and judgment, particularly when faced with difficult situations where we are confronted with the risk to compromise our integrity or our values.
The EPP needs this Code of Ethics and Professional Conduct in order to ensure its role as open and unbiased platform – and beliefs that we advance our profession, both individually and collectively, by embracing both the mandatory and the aspirational standards that we strive to uphold as pricing professionals.
1.2 Persons to whom the Code of Conduct applies
By becoming a participant and/or getting involved in activities of the EPP, individuals agree that they accept this EPP Code of Ethics and Professional Conduct and the Complaints procedure, which applies to all activities and events of the EPP.
The Code of Ethics and Professional Conduct applies to:
1.2.1 All EPP staff.
1.2.2 All EPP participants.
1.2.3 All EPP trainers.
1.2.4 Individuals who are not a participant of the EPP but meet one or more of the following criteria:
- Non-participants who hold an EPP certification (CPM);
- Non-participants who apply to commence an EPP (CPM) certification process;
- Non-participants who attend an EPP event, workshop or training;
- Volunteers, who attend, organise and/or speak at an EPP event.
Mandatory standards – legal obligations
These mandatory standards of conduct have to be followed by all participants, partners and non-participants since they are required to do so by direct laws and or regulations. The EPP mandatory standards stipulate the following explicit principles and rules.;
2.1. No anti-competitive arrangements
During all, on- and offline, meetings and events, it is prohibited to make any agreement that infringes, or possibly may infringe effective 'competition laws'. This includes:
- The direct or indirect fixing of (horizontal or vertical) prices or any other trading condition;
- Limitation or control of production, markets, technical development or investments;
- Sharing markets;
- Agreements regarding the common refusal to supply;
- All written or oral agreements and practices between undertakings which have as object or effect the prevention, restriction or distortion of competition law are prohibited.
2.2. No exchange of commercially sensitive information
The exchange of general information on pricing and a description or general discussion about the problems regarding pricing is in principle permitted. Exchange of information is mainly prohibited when it is company specific and can therefore be used (among other things) for controlling fulfilment of existing pricing, production or market partition agreements or other agreements which infringe effective competition.
2.3. About the use of calculation schemes
When calculation schemes are formulated by participants or by the organisation explaining which items are relevant for calculating prices, only objective information which makes it easier to make a cost structure can be provided. The calculation scheme or information drawn from the scheme cannot be directional for the pricing policy of participants. The scheme may not lead to elimination of the normal uncertainty in the market about the (intended) market behaviour of market participants.
2.4. Responsibility to report infringements
Every participant has the obligation to report any infringement of the competition law that he or she observes during EPP activities to the EPP organisation. In order to maintain a state-of-the art pricing knowledge-sharing platform, it is important for all participants that we assure to prevent all prohibited behaviour taking place within the context of the activities organised by the European Pricing Platform. For more information see §4.2.
Aspirational standards - based on shared values and norms
The aspirational standards describe the conduct that we strive to uphold as practitioners. The core values that the EPP community defines as most important are : open and unbiased, responsibility and respect.
This Code of Ethics affirms these three values as its foundation. Although adherence to aspirational standards is not easily measured, norms have been defined to evaluate if conduct is in accordance with the expectation that we have of ourselves as pricing professionals.
3.1. Open and unbiased
- Being open and unbiased means that we do not exclude anyone involved in the pricing profession from joining the platform and attending events of the EPP. Both the EPP and participants win by ensuring an open platform of discussion and learning;
- The EPP is unbiased without favoritism or prejudice towards anyone of the participants, companies, partner-companies or sponsors;
- The EPP provides objective and general information enabling everyone involved in pricing to develop pricing maturity in their organisations.
- The EPP is unbiased towards people and organisations willing to attend and or cooperate with the EPP as long as adherence to the Code of Ethics and Professional Conduct is respected;
- Clear and objective information communication is the norm in all our (on- and off line) communication and during all EPP events. We expect the same of all our participants, non-participants, partners and volunteers.
Responsibility is our duty, this means to take ownership for the decisions and actions we make or fail to make, and the consequences that result.
- Pricing practitioners commit to inform themselves and uphold the policies, rules, regulations and laws that govern our work, professionals, and activities. They commit to report unethical or illegal conduct to appropriate management and, if necessary, to those affected by the conduct;
- If the EPP beliefs that a possible conflict of business interest could arise (e.g. if a sponsor of partner does not want to share its information or intellectual property with competitive representatives), the EPP could be forced to exclude organizations/people for (a part) of an event/session.
- Respect is our duty, this means to show a high regard for ourselves, others and the resources entrusted to us. Resources entrusted to us may include people, money, reputation, the safety of others, and natural or environmental resources;
- We listen and seek to understand, we approach directly those persons with whom we have a conflict or disagreement to discuss and solve the issues, we respect the (intellectual) property rights of others.
- We respect each other’s points of views in our discussions, we listen to understand;
- Pricing practitioners, and the EPP, have a proactive attitude towards and fully discloses any real or potential conflicts of interest to the appropriate stakeholders;
- Presenting/use (both off- and/or online) of any material using intellectual property of other professionals can only be accepted when :
a) prior authorisation of the author is given, and/or;
b)the user clearly indicates/mentions the source of the material.
- Unauthorised use and/or presentation of material without source indication are of course an infringement of intellectual property - and a violation of this Code of Ethics.
4.1 Ethics Complaints
We believe that we can advance our profession, both individually and collectively, by embracing this Code of Ethics and Professional Conduct. Therefore the pricing and profit optimisation management community takes its commitment to the Code of Ethics and Professional Conduct very seriously and we hold ourselves and our peers in the pricing community accountable to conduct ourselves in accordance with the provisions of this Code of Ethics and Professional Conduct.
In case of a violation of this code, either in the form a or an ethical complaint the EPP will review this complaint and when necessary refer this to the independent Complaint Committee. The EPP takes all ethical cases brought to its attention very seriously and all cases are reviewed and acted upon as needed.
4.1.1 Violations of this Code under Chapter three should be brought to the attention of the appropriate body for resolution, always accompanied by a complete Complaint form. In the case of any violations of what is mentioned under Chapter two, there is an obligation to report this, see § 4.2.
4.1.2 The EPP encourages to only file ethics complaints when they are substantiated by facts. Only if all the facts are collected can the EPP objectively review the ethical complaint.
4.1.3 The EPP will review whether or not the complaint is an ethical complaint, if this is not the case then this complaint will not be reviewed. This will then be communicated to the person(s) complaining. When the complaint is admissible, the EPP will review this complaint, or refer this complaint to our Complaint Committee.
4.2 Reporting Infringement of Mandatory regulations
Every participant has the obligation to report any infringement of the mandatory regulations that he or she observes to the proper authorities, during EPP activities. See Chapter two, in particularly § 2.4.
4.3 Complaint form
4.3.1 Individuals seeking to file an ethic complaint must complete an ethics complaint form. The completed ethics complaint form must be printed out, signed, marked confidential and mailed with supporting documents to: email@example.com.
4.3.2. After the Complaint Form has been received the EPP will review the complaint, when the complaint is admissible either the EPP or the Complaint Committee will review the complaint. After receiving the complete complaint form the complaint procedure will be initiated.
4.4 Complaint procedure and complaint Committee
The procedure of filling a complaint, can be found in the ethical complaint procedure promulgated by the EPP. These procedures are applicable to all persons to which this EPP Code applies – as stated under § 1.2.Individuals that are covered by this Code understand and agree that these procedures are a fair process for resolving all ethics matters duly adopted by EPP; and they will be bound by decisions made, and requirements issued, pursuant to these procedures. For the entire procedure click here>
4.4.1 The EPP has installed an independent Complaint Committee that considers the complaint and resolves the ethic matter in question, when the EPP cannot. In every case the EPP board has a final say in any case of an ethical complaint, when the complaint is admissible the ethical complaint can be referred to the Complaint Committee. The Complaint Committee is formed by Chapter Board Leaders of our Chapter Boards. The Committee will always have a composition of an uneven number, so either 3, 5 or 7 people. A majority of the votes (meaning ¾) is necessary to make any decision within the Committee.