LAND O’LAKES, INC. // CODE OF CONDUCT
SCENARIOS “CO-OPITITION” Land O’Lakes is in early discussions with Company X about forming a joint venture. Company X is currently a competitor to Winfield United. During a meeting, the VP of Sales at Company X offers you a list of their customers, products and prices. What should you do? Sometimes a competitor can be a customer (or even a business partner), making it difficult to know where “competition” stops and “cooperation” begins. In this scenario, despite the potential joint venture, the competitive information cannot be shared until cleared by the Law Department. Do not accept the information and then document what happened—and how you responded—as soon as possible.
TRADE ASSOCIATION EVENTS You are participating at a roundtable event during a trade show where competitors are present. The first topic is an effort to lobby for changes to laws that will make it easier to bring new technologies to market. The conversation then turns to standardizing industry credit and payment terms, which would be a big boost to efficiency. Should you be concerned? Lobbying efforts by a trade association are permissible, even when they are undertaken among competitors. However, when the conversation turns to credit and pricing terms—both a component of pricing—you should make a “noisy exit,” meaning you stop the conversation, state that you cannot participate in it and ask that all note the point at which you left the conversation. Contact the Law Department immediately for further guidance.
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