Statement of Policy
The Kansas Self Storage Owner’s Association (KSSOA) recognizes and acknowledges the importance of preserving a free, competitive economy in the United States. It is KSSOA’s policy to avoid any conduct or discussion that would constitute, or which could be construed as, restraining competition among competitors through agreement, understanding or otherwise, as to the price, production, or distribution of their products, or other agreements which unreasonably restrict competition, or restrict the competitive capabilities or opportunities of their competitors, their suppliers or their customers.
As unlawful agreements can sometimes be inferred from circumstantial evidence, it is the intention of this organization to avoid even the appearance of questionable activity. Accordingly, all KSSOA meetings of every kind will be conducted in accordance with the following procedures:
There will be no discussion at any time of:
- Current or future prices.
- What constitutes a "fair profit level."
- Possible increases or decreases in prices.
- Standardization or stabilization of prices.
- Pricing procedures.
- Cash discounts.
- Credit terms.
- Control of sales.
- Allocation of markets or geographical division of markets.
- Refusal to deal with a corporation because of its pricing or distribution practices.
- Whether or not the pricing practices of any industry member are unethical or constitute an unfair trade practice.
It is the policy of KSSOA and its members to comply strictly with all laws applicable to KSSOA’s activities. Because such activities involve cooperative undertakings and meetings among competitors, the Board of Directors emphasizes the ongoing commitment of KSSOA and its members to full compliance with federal and state antitrust laws. A statement explaining this policy is to be made available at all KSSOA meetings to remind each member of this commitment and as a general guide for our activities and meetings.
Responsibility for Antitrust Compliance
KSSOA's programs have been designed and reviewed to ensure their conformity with antitrust standards. Each KSSOA member has an equivalent responsibility for antitrust compliance. Each business enterprise and KSSOA depend upon good judgment by all to avoid discussions and activities which could involve improper subject matter or improper procedures, or even an appearance of improper activity. KSSOA staff members work conscientiously to avoid subject matters for discussion which may have unintended implications, and counsel for KSSOA provides guidance with regard to these matters. All concerned have an important and individual responsibility for assuring antitrust compliance in KSSOA activities.
To avoid even the appearance of questionable activity, as well as to guard against inadvertent conduct, all KSSOA meetings shall follow these guidelines:
- A written agenda will be prepared.\
- Accurate minutes of every meeting will be prepared, expeditiously sent to the participants, and approved at the next meeting.
- These guidelines will be posted at all board meetings and be som noted in the minutes.
- In case of doubt about the propriety of a topic of discussion, consult KSSOA officers or corporate counsel.
- If a member has a reservation concerning remarks or discussion at an KSSOA meeting, officially state the reservation; if the discussion is not terminated or resolved satisfactorily, the concerned member should leave the meeting.
- Post-meeting chat sessions involving the discussion of business matters should be avoided.
These guidelines are intended to highlight and emphasize the commitment of this organization to abide by the spirit of the law, and to set forth general, basic precautions designed to avoid not only antitrust violations, but any behavior which might be considered improper as well.
In case of doubt, seek the guidance of KSSOA counsel, the officers of KSSOA or your own corporate counsel if antitrust questions arise.