SFF-8023 Rev 1.0 SFF Committee documentation may be purchased in hard copy or electronic form. SFF specifications are available at ftp://ftp.seagate.com/sff SFF Committee Antitrust Guidelines Rev 1.0 January 28, 2007 These guidelines have been documented for the protection of SFF Committee and SFF SSWG participants on antitrust issues. SFF Committee and SFF SSWGs must be conducted in a manner that avoids the appearance of conduct which might violate the antitrust laws. The harsh criminal penalties in the antitrust laws, for individuals as well as organizations, the high costs of defending antitrust suits, the diversion of resources from our important missions, and the risk of liability together mandate an understanding of, and respect for, the antitrust laws by participants in the SFF Committee. The objective is to create a climate where antitrust risks are both anticipated and avoided. Any member who anticipates a matter which could raise antitrust issues should contact the Chairman as soon as possible before the meeting or SSWG starts to advise of the possibility. Each meeting or SSWG shall identify the policy in the agenda so that everyone in attendance is aware that these antitrust guidelines are available at ftp://ftp.seagate.com/sff/SFF-8023.PDF All SFF Committee members in a meeting or SSWG shal be afforded an opportunity to present their views. In the event that discussion could be construed as raising questions under the SFF Committee antitrust guidelines, the chair or leader has the responsibility to terminate any discussion, even to the extent of terminating the meeting or SSWG. Concise minutes prepared after each SFF Committee meeting must accurately describe the actions taken, the justification for those actions, and where appropriate, additional pertinent discussion. Any member who feels the minutes are deficient can request that they be revised. It is required that minutes be prepared after every SFF SSWG meeting, and strongly recommended that they be prepared after a telecon. All persons present are responsible for identifying potential violations of the antitrust guidelines and reporting them to the chair. Any person present is responsible to object if he/she believes a discussion violates those guidelines. Sharing non-proprietary information among competitors is generally lawful, and discussion should be limited to objectives, which promote overall consumer welfare. Exchanging proprietary information is not appropriate if the purpose or effect of the exchange is to lead to diminished competition in the marketplace. Some topics are considered sensitive and should never be covered SFF Committee Antitrust Guidelines Page 1 SFF-8023 Rev 1.0 at a meeting e.g. - Any company's prices or pricing policies; - Specific R&D, sales and marketing plans; - Any company's confidential product, product development or production strategies; - Whether certain suppliers or customers will be served; - Prices paid to input sources; or - Complaints about individual firms or other actions that might tend to hinder a competitor in any market. SFF Committee meetings and SSWGs shall consider all opinions, and where applicable decisions must be made on a sound technical basis. Any member participating in another standard-setting body on behalf of the SFF Committee should be guided by both the letter and the spirit of these guidelines to ensure that the process is open to all interested parties and specifications are based on objective technical factors. SFF Committee members should voluntarily disclose any proprietary interest they may have in proposed standard in order to reduce the risk of antitrust liability. SFF Committee Antitrust Guidelines Page 2