Safeway (SWY)

Antitrust Laws

Antitrust laws are designed to protect competition. In general, they forbid any agreement that restrains trade. Safeway has a long-standing policy of complying fully and in every respect with all antitrust laws that apply to its operations. Compliance is vital to the Company and each employee.

No employee of the Company may have any discussion or communication with any representative of a competitor concerning past, present or future prices, pricing policies, bids, discounts, promotions, terms or conditions of sale, royalties, choice of suppliers, allocation of territories, sales or customers, limitations on production or distribution, or future location of stores. In addition, discussions with competitors concerning costs, including labor rates and cost of goods and services, can be sensitive from an antitrust point of view and any such discussions should be reviewed in advance with the Legal Division. It follows, of course, that there never must be any agreement, express or implied, with a competitor concerning any of these subjects. This includes formal agreements, as well as tacit understandings and informal “off the record” conversations.