UK Competition law prohibits all forms of restrictive agreements and concerted practices
between companies. Such prohibited practices extends to directly or indirectly fixing purchase
or selling prices and includes non-binding arrangements, ‘understandings’ and other types of
informal collusion. Indirect price fixing is a criminal offence.
The Competition and Markets Authority has the power to impose fines for breach of the UK
Competition rules. Third parties can also bring in private damage actions. STEP itself could
become liable for breaches of Competition law where it is said to facilitate anti-competitive
actions and such a breach could have both financial and reputational consequences for STEP.
In the circumstances, when using the forum STEP requires that:
• Members should not discuss competitively sensitive information;
• Members should report to STEP any conversation where competitively sensitive
information is discussed.
Competitively sensitive information covers any non-public strategic information about a
business’ commercial policy and includes future pricing and output plans.
In simple terms, this means:
• Please do not use the forum for discussing prices, price increases or costs with
• Please do not use the forum to calculate prices interdependently with respect to
• Please do not exchange confidential commercially sensitive information with
With thanks for your understanding,
STEP Professional Standards