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Antitrust & Competition Law Policy
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GlobalEVP, General Counsel & Corporate Secretary
MVP, Ethics & Compliance
April 2024

Policy Philosophy & Purpose
Antitrust laws are intended to promote competition and are designed to prevent
business practices that reduce competition, either through collusive activity among
competitors or using a strong market position to exclude rivals. In the US, these laws
are referred to as “Antitrust laws”; outside the US, they are often referred to as“Competition laws”. When companies compete based on price, product quality, andinnovation, consumers are better off.

Scope & Applicability
Gartner expects its associates to comply with applicable Antitrust and Competition
laws everywhere we do business. This policy applies to Gartner associates and all
individuals participating in Gartner-hosted peer activities.

PolicyThis Policy helps associates and individuals who participate in Gartner-hosted peer
activities understand their obligations under global antitrust and competition laws. All
associates are expected to escalate to Gartner Legal & Compliance(legalcompliance@gartner.com) any specific situation that may pose antitrust risks for
Gartner or our clients. If any non-associate has any questions or is in doubt about aspecific situation, they are encouraged to consult their own legal counsel before
engaging in Gartner Peer Activities.
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Gartner reserves the right to add, modify or delete any provisions of this policy
without advance notice, subject to the requirements of local law, where applicable.
© 2024 Gartner, Inc. and/or its affiliates. All rights reserved. Gartner is a registeredtrademark of Gartner, Inc., or its affiliates. Version 2.0 Last updated March 2024

Associates who violate this policy may be subject to disciplinary action up to andincluding termination of employment.

General Compliance and Guidelines
The following are examples of common behaviors to avoid; it is not an exhaustive
list. Even if a particular situation is not expressly mentioned, it may violate global
antitrust and competition laws:
1. Collusion: coordination among competitors regarding prices, fees, terms, bids,customers or boycotts.
a. Price Fixing: agreements among competitors on any element of price or
price terms (e.g., discounts, rebates, pricing formulas, credit terms);
b. Bid-Rigging: agreements among competitors to influence an otherwisecompetitive bidding process; and/orc. Group boycotting: agreements among competitors not to do business withtargeted individuals or businesses.
2. Hub-and-Spoke Conspiracy: a common party (the “hub”) facilitates illegal
agreements (such as price fixing, bid-rigging, market allocation, or groupboycotting) among competitors (the “spokes”).
3. Market Allocation: agreements among competitors to divide territories,
customers, suppliers, products, or levels of output.
4. Non-Poaching or Wage Fixing Agreements: suggesting or agreeing withanother company not to hire each other’s employees, or to set specific wages
or terms of employment.
To protect against the possibility of engaging in anticompetitive behavior, whenengaging in meetings that include Gartner competitors, associates should (1) speak
up if the discussion touches on any of the subjects outlined above, (2) leave themeeting, and (3) alert Legal & Compliance (legalcompliance@gartner.com)
immediately. See the appendix for a Quick Reference Guide.

Peer-Facilitated Activities
Various Gartner product offerings contain a peer activity component where Gartnerbrings together clients and other third parties with similar job roles. They may be in
the same or different industries and are brought together to exchange knowledge,
impart insights, and share best practices related to their mission-critical priorities, key
initiatives, and challenges. Sometimes, associates moderate or facilitate these
discussions (i.e., during Gartner Research Board, Peer Community, Global PeerIndustry Forums, Conferences, and EXP Academies (collectively “Peer Activities”)).
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Gartner reserves the right to add, modify or delete any provisions of this policy
without advance notice, subject to the requirements of local law, where applicable.
© 2024 Gartner, Inc. and/or its affiliates. All rights reserved. Gartner is a registeredtrademark of Gartner, Inc., or its affiliates. Version 2.0 Last updated March 2024

During Peer Activities, all participants must be sensitive to discussion topics thatmight implicate antitrust and competition laws.
To remind clients and third parties of their responsibilities as Peer Activity
participants, the Antitrust & Competition Guidelines should be displayed prominently
at the beginning of every Peer Activity. This slide also contains the QR Code and linkto this Policy. If this slide is visible to all participants, there is no need to read aloudthe information; however, the host should draw attention to the slide before moving
on to subsequent material.
Every Gartner Peer Activity participant is responsible for complying with applicable
antitrust and competition laws.

Trade Associations
From time to time, associates attend trade association meetings. In those situations,associates should be careful not to share competitively sensitive information withother participants. They must be mindful that when attending a trade association
meeting, they are not engaging in any of the prohibited activities listed in this Policy.

Speak UpIf you are concerned that the law or this policy has been or may be violated, it isimportant that you speak up. If you have a question, are confused, or a situation “justdoesn't feel right,” it is always better to ask for help.
Speak Up Reporting Channels
These are the reporting channels to use to raise a question or concern. Feelfree to choose the channel with which you are most comfortable:
1. Talk to your manager. associates may start by talking to theirmanager. If unable to provide an answer, it’s the manager’s job to help
Gartner associates find one or escalate a complaint.
2. Talk to someone outside your team. associates may always talkwith any other manager in their business unit, their (or any other)
Human Resources partner, or Legal & Compliance.
3. Contact the Gartner Helpline. Our third-party helpline allows
anyone (associates and non-associates) to report anonymously 24hours a day, 7 days a week, in many different languages. Contact thePage 3
Gartner reserves the right to add, modify or delete any provisions of this policy
without advance notice, subject to the requirements of local law, where applicable.
© 2024 Gartner, Inc. and/or its affiliates. All rights reserved. Gartner is a registeredtrademark of Gartner, Inc., or its affiliates. Version 2.0 Last updated March 2024

Gartner Ethics Helpline — you will find a link to toll-free numbers and a
way to report online.
Associates who violate this policy may be subject to disciplinary action up to andincluding termination of employment.
We do not tolerate retaliation
Gartner does not tolerate retaliation of any kind against anyone who reports aconcern in good faith. Associates that engage in retaliatory behavior will be subject todisciplinary action, up to and including termination of employment.

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Gartner reserves the right to add, modify or delete any provisions of this policy
without advance notice, subject to the requirements of local law, where applicable.
© 2024 Gartner, Inc. and/or its affiliates. All rights reserved. Gartner is a registeredtrademark of Gartner, Inc., or its affiliates. Version 2.0 Last updated March 2024

Appendix A
Quick Reference Guide
Use the below guidance to remain compliant with this policy and antitrust andcompetition laws.
Allocation, Demand & Refusal to Deal
Avoid
● Agreeing to fix product quality or quantities.
● Agreeing to future plans to fix production capacity.
● Agreeing to opportunities to win specific customers.
● Making any agreements regarding allocation of customers or geographic
territories or markets.
● Disclosing expansion or retraction plans or production capacity or forecast
future ability to meet market demand.
● Disclosing revenues attributable to specific customers or refusing to deal witha specific customer or supplier.
● Implementing strategies to refrain from competing for certain customers or incertain countries in exchange for not having to face competition from anothercustomer or in another country.
● Making any agreements regarding a joint action that may be taken against acustomer, supplier, distributor, or competitor, or jointly attempting to prevent a
supplier from selling to your competitor(s).
● Making any statements that could be interpreted as an invitation to coordinate
behavior, such as collectively agreeing not to do business with a certain
customer or competitor.
Discuss● Effects of government legislation.
● General industry interests, experiences or opinions.
● Historic, aggregated, and statistical market data.
Bid Rigging
Avoid● Agreeing in advance that a company will win a bid, taking turns being thelowest bidder, intentionally sitting out of a bidding round, or providing
intentionally high bids to cover up a bid-rigging scheme.
● Engaging in any discussions where participants agree not to pay more than acertain amount for a certain product.
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Gartner reserves the right to add, modify or delete any provisions of this policy
without advance notice, subject to the requirements of local law, where applicable.
© 2024 Gartner, Inc. and/or its affiliates. All rights reserved. Gartner is a registeredtrademark of Gartner, Inc., or its affiliates. Version 2.0 Last updated March 2024

Client Confidential Information
Avoid● Disclosing any confidential, client-specific information to a third party.
Entering New Markets
Avoid● Agreeing to forego entering new lines of business because a participant’scompetitor dominates them.
● If your company is entering into a new industry, discussing with anothercompany in that same industry the terms on which you should or should notcompete in that market.
Discuss● Keeping your discussions high-level and focused on general tips and advice
about entering new markets.
Press Releases and Communications to the Public
Avoid● Discussing press releases since they may be interpreted as an invitation tocoordinate announcements with other participants. Ex.: “Let’s meet next week
to send out press releases regarding our capacity."
Price FixingAvoid● Discussing company-specific price-setting methodologies, making comments
regarding past, current or future pricing for specific companies unless thisinformation is publicly available or generally known, or discussing/agreeing on
prices that specific companies will charge their customers.
● Engaging in discussions regarding specific prices, fees, or rates.
● Having any discussions where participants agree not to pay more than acertain amount for a certain product.
● Saying, “Something needs to be done about low prices,” which may beinterpreted as an invitation to the group to raise prices.

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Gartner reserves the right to add, modify or delete any provisions of this policy
without advance notice, subject to the requirements of local law, where applicable.
© 2024 Gartner, Inc. and/or its affiliates. All rights reserved. Gartner is a registeredtrademark of Gartner, Inc., or its affiliates. Version 2.0 Last updated March 2024

StrategiesAvoid● Agreeing on a joint strategy relating to the operation of your business.
● Disclosing your company’s commercial strategy (which may be interpreted as
an invitation to coordinate strategies or to otherwise enable a coordination ofstrategies).
● Discussing commercially sensitive, strategic, or confidential information.
Terms and Conditions
Avoid● Agreeing with other participants to coordinate.
● Aligning legal terms, conditions, including licenses or provisions, as a meansof dealing with certain customers or suppliers that you have in common.
● Sharing or compare company-specific legal or contract templates or companyspecific contractual provisions that are not publicly available or generallyknown.

Additional Resources
Department of Justice Tip Sheet
Federal Trade Commission - Competition Guidance - Guide to Antitrust Laws

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Gartner reserves the right to add, modify or delete any provisions of this policy
without advance notice, subject to the requirements of local law, where applicable.
© 2024 Gartner, Inc. and/or its affiliates. All rights reserved. Gartner is a registeredtrademark of Gartner, Inc., or its affiliates. Version 2.0 Last updated March 2024