Code of Conduct

Table of Contents

Know About the Code 3

Who Must Follow the Code? 3

Violation of the Code 3

Know Your Responsibilities 3

Speak Up 4

Non- Retaliation 4

I. Respect Each Other 4

1. Equal Opportunity Employment 5

2. Discrimination and Harassment 5

3. Workplace Safety 5

4. Drugs and Alcohol 6

II. Avoid Conflicts of Interest 6

1. Personal Investments 6

2. Outside Work 7

3. Inventions 7

4. Personal Relationships 7

III. Protecting Confidentiality 7

1. Confidential Information 8

2. Social Media and External Communications 8

3. Personal Data Protection and Privacy 9

IV. Protecting Company Assets 9

1. Intellectual Property 10

2. Company Property 10

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V. Ensure Financial Integrity and Responsibility 10

VI. Obey the Law 11

1. Anti Bribery & Anti Corruption 11

Anti-Bribery, Kickbacks, and Facilitation Payments 11

Gifts, Meals, and Entertainment 11

Employment and Internships 12

Political Contributions and Charitable Donations 12

Sponsorship 12

2. Anti Money Laundering & Combating the Financing of Terrorism 13

3. Related Party Transaction 13

4. Insider Trading 13

5. Anti Trust and Competition 14

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Know About the Code
PT GoTo Gojek Tokopedia Tbk, (hereinafter, the “Company”) believes that the success and sustainability
of our business depends largely on how we behave and run the business. Doing the right thing by
following the applicable laws and regulations, working with integrity and treating each other with respect is
our way to realize the core values to be an agile and compassionate company.

Our commitment to act ethically and responsibly is reinforced through our Code of Conduct (the “Code”)
as a center of everything in doing our work. This Code serves to remind us and guide us to always use
our good ethical judgement in every situation. In this way, we can conduct business according to the
highest level of integrity and ethical standards and to build a culture of trust for our business sustainability.

Who Must Follow the Code?

The Code applies to all members of the Board of Directors, the Board of Commissioners, officers,
employees (permanent or non-permanent, regardless of location) (collectively “Company Personnel” or
“You” whenever required by the context), including its affiliates. In addition, it also applies to all related
third parties, including but not limited to contractors, drivers and business partners, consultants and
others of any representative who may be associated with the Company to perform work or services are
expected to follow the Code.

Violation of the Code

Our Company has zero tolerance for unethical business conduct. We take things very seriously for every
instance of non-compliance with the Code. The Company will impose disciplinary actions up to and
including dismissal or termination for a verified violation report of the Code, such violation may also be
subject to certain administrative and/or civil and criminal sanctions as provided under the applicable laws
and regulations. For further provisions on disciplinary actions, you may refer to the relevant policy
regarding disciplinary and corrective action.

Know Your Responsibilities

As part of the Company, we are all responsible for understanding and complying to the Code as well as to
the Company policies, procedures, and applicable laws and regulations that apply to the work that we do.

In doing our daily work, we must play an active role in creating an environment that is free from unethical
behaviour. Be a role model by always being honest and using our good ethical judgement in our business
dealings internally and externally.

All Company Personnel should actively demonstrate the highest level of quality and ethical standards at
all times. It is important for everyone to create an environment where all team members can speak up and

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raise their concerns. Company Personnel are required to listen and report improper behaviour or
misconduct and never engage in or encourage retaliatory behaviour.

The Code may not have all the answers to every situation, hence it is our responsibility to seek guidance
from the appropriate Company function. When encountering any suspected unethical behaviour or
misconduct that occurred in the workplace, we must speak up and report it.

Speak Up
Part of building a culture of trust is by daring to speak up when something is not right.

If You see or suspect any violation to the Code, raise your concerns to your supervisors or submit a report
with truthful and accurate information through our whistleblowing channel.

You can submit the report through a whistleblowing email: ethics@gotocompany.com. Reports are
accepted anonymously where permitted by law. Your reports will be reviewed and addressed according to
our Whistleblowing Policy.

Whistleblowing reports are treated seriously, with full confidentiality, and will be resolved in line with
Company policy and applicable laws and regulations.

Non- Retaliation

Non-retaliation means that persons submitting a whistleblower report will not be punished for reporting a
violation or suspected violation.

Our Company does not tolerate any form of retaliation against anyone who makes a report in good faith. If
You feel you are facing retaliation for submitting a report, please send an email to the whistleblowing
email: ethics@gotocompany.com.

I. Respect Each Other

Our Company has a zero tolerance policy towards any form of harassment and prohibits discriminatory
practices that may distress or inhibit a member of Company Personnel.

In creating a supportive work environment, where all Company Personnel have the opportunity to realize
their fullest potential, we uphold the core principles of fairness, transparency, and accountability. In line
with such core principles, we are committed to create a work environment free from discrimination,
bullying, harassment, and any form of violence. All parts of the Company are expected to participate in
creating a respectful and caring workplace.

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1. Equal Opportunity Employment
As we all come from different backgrounds, our Company is committed to mutual respect and
embracing diversity. Employment (hiring, promoting and compensating) is based solely upon
individual merit and qualifications directly related to professional competence.
We respect and value Company Personnel from all backgrounds, regardless of race, colour, gender,
political opinion, ethnicity, national or social origin, ancestry, socioeconomic background, pregnancy
status, marital status, age, sexual orientation, religion, mental or physical disability, medical condition,
personality, and work experience, which has the effect of nullifying or impairing equality of opportunity
or treatment in employment or occupation. We have to ensure that people of diverse backgrounds
feel welcome, engaged, valued and safe to bring their best and authentic selves to work every day.
Creating a diverse, equal and inclusive culture makes us a more innovative, productive, resilient and
responsible Company.

2. Discrimination and Harassment

Our Company doesnot tolerate any form of unlawful discrimination and harassment. Our Company
environment is characterized by mutual trust and the absence of intimidation, oppression and
exploitation. Our group-wide Prevention of Workplace Discrimination and Harassment policy and the
supporting mechanisms ensure that all Company Personnel are protected, no matter where they are
working. For our partners and users, we are committed to raising awareness of the different types of
harassment, and ensuring our ecosystem has the right protective mechanisms to eliminate it
altogether.

If You believe you are being or have been discriminated against or harassed by anyone at the
Company, or by our business partners, immediately report the incident to our whistleblowing email:
ethics@gotocompany.com.

Company Personnel who knowingly allow or tolerate discrimination, harassment or retaliation,

including the failure to immediately report such misconduct to People and Culture Team, are in
violation of this policy and subject to disciplinary or corrective actions.

*) Discrimination & Harassment: behaviors using any medium verbal, electronic, visual, gestural, written or graphical, physical
that tend to annoy, alarm, abuse, demean, intimidate, belittle, humiliate or embarrass or another or that create an intimidating,
hostile, or offensive work environment.

3. Workplace Safety
We are responsible for establishing a safe, secure and hazard-free place to work. Violence of any
kind is prohibited. Any behaviour that threatens the safety and security of Company Personnel, our
partner and users is not acceptable. Weapons of any kind are prohibited in the workplace (e.g.
knives, blunt heavy objects). If You are in a situation where there is a risk to the safety and security of
you or anyone else, contact the Workplace/ Office Management function immediately.

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4. Drugs and Alcohol
Company Personnel are required to comply with the prevailing laws and regulations in their relevant
jurisdiction in relation to the use and/or possession of drugs and alcohol. All Company Personnel are
advised to avoid anything that jeopardizes their and others' security, health and safety.

If You suspect that a member of Company Personnel is under the influence of drugs or alcohol during
working hours that is, or has the potential, to adversely affect that person's job performance or the
safety of others in the workplace, make an immediate report to the People and Culture Team or
People Team.

II. Avoid Conflicts of Interest

In principle, a conflict of interest arises when there is a conflict between the interests of the Company and
the personal interest of Company Personnel which will benefit the relevant Company Personnel.
An example of conflict of interest occurs when You are in a situation where the course of action You take
brings an incentive for You, or can benefit yourself and/or your affiliates, but is at the expense of the
Company or of our users.

Company Personnel are required to avoid circumstances which may lead to an actual or potential conflict
of interest which include, but are not limited to direct or indirect incentives, personal investments, outside
employment or business opportunities, and inventions, patents, or trademark registrations. In addition,
Company Personnel must also be aware of the potential conflicts of interest which may arise from their
personal relationships.

Upon becoming aware of a possible or actual conflict of interest, You are required to immediately report
and disclose such conflict to the whistleblowing email: ethics@gotocompany.com.

1. Personal Investments
Refrain from making personal investments in companies that are our competitors (whether direct or
indirect) or business partners when the investment may cause, or appear to cause, You to act in a
way that could jeopardize the Company.

Company Personnel must:

● Always consider their shareholding and the influence over the management or control they may
have over an outside company and its potential to trigger a conflict of interest.
● Not undertake a personal investment that creates a conflict of interest with our Company.
● Upon becoming aware of a potential or actual conflict of interest as a result of personal
investment Company Personnel must immediately disclose their shareholding and/or investment
which creates conflict of interest to the appropriate Company function for assessment.

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2. Outside Work
In principle, Company Personnel are required to avoid accepting employment outside the Company,
including but not limited to, advisory positions or board seats with other companies, including our
competitors or business partners in a way that could harm the Company.

Board positions come with fiduciary obligations that may give rise to conflict of interest, Company
Personnel must notify and declare it to the appropriate Company function before accepting a board
position with any outside company. Finally, do not start your own business if it may compete with the
Company, also bear in mind that business opportunities discovered through your work within the
Company belong first to the Company, except as otherwise agreed to by the Company.

3. Inventions
Developing or helping to develop outside inventions that relate to Company’s existing or reasonably
anticipated products and services, relate to your position at the Company, or are developed using
Company corporate resources, may create conflicts of interest and be subject to the Company’s
Confidential Information. If You have any questions about potential conflicts or intellectual property
ownership involving an outside invention or other intellectual property, please consult through a
whistleblowing email: ethics@gotocompany.com.

4. Personal Relationships
Certain personal relationships between Company Personnel and their friends (including co-workers),
family and relatives have the potential to affect performance, objectivity, fairness and integrity in work
relationships and decision-making and the fulfillment of their responsibilities at our Company. This can
negatively impact Company’s ability to recruit and retain employees and otherwise diminish our
Company reputation for ethical and fair conduct.

Company Personnel must always be mindful of the impact of their personal relationships towards
Company Business and their potential to give rise to conflicts of interest. Business decisions must not
be influenced by any personal relationship whether familial, romantic or otherwise or by membership
in any social, religious or political association.

In case of doubt or upon becoming aware of a potential or actual conflict of interest, Company
Personnel need to consult through a whistleblowing email: ethics@gotocompany.com.

III. Protecting Confidentiality

Be careful to avoid the inadvertent disclosure of confidential information (as defined below) belonging to
the Company, our business partners or other related third parties. The Company’s responsibilities extend
beyond not revealing confidential information but to proactively ensure its safeguarding in accordance
with applicable laws and regulations and to the highest standard possible in the industry.

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1. Confidential Information
Confidential Information (hereinafter “Confidential Information”) refers to any information relating to
the Company which is not intended for public use or use outside of the Company including but not
limited to commercial, financial or technical information or information relating to users, Company
Personnel, business partners and other related third parties. Confidential Information must at all times
be kept confidential pursuant to all applicable laws and regulations as well as industry best practices.

To ensure the protection of Confidential Information, the following requirements must be adhered to:
● Company Personnel must protect the Confidential Information owned by or entrusted to the
Company and are prohibited from disclosing such information without valid authorization,
ensuring appropriate safeguards and prior due diligence. Any handling of Confidential Information
must take into consideration the protection of the Company’s competitiveness and its reputation.
● Any disclosure of Confidential Information must be done on a “need-to-know” basis subject to a
duly executed and binding non-disclosure agreement with an emphasis on minimal necessary
disclosure.
● Confidential Information may also be subject to other legal rights such as but not limited to
intellectual property and personal data protection rights and must be protected according to those
standards.
● Company Personnel are required to exercise prudence and good judgment in preventing the
inadvertent disclosure of proprietary and Confidential Information.
● We are committed to fair and ethical competition in our business and do not make use of
Confidential Information relating to our competitors that is not disclosed in good faith.

2. Social Media and External Communications

We are all proud of our Company and it is natural that we might want to share the great things we are
doing but only share and amplify data and information that has been approved by Corporate Affairs.

Even if information is positive and not considered confidential only share it if it has been approved by
Corporate Affairs or Corporate Communication has released the information publicly (in a media
release, or on a post on our official sites, for example), and ensure to cite any sources that you use

In addition to restricting your Social Media posts and public conversations about the Company to
pre-approved content, the following must be taken into account:
● Always be mindful and aware that we have a large number of direct and indirect stakeholders
who may interpret conversations about our Company differently.
● Do not engage in negative discussion topics or arguments on social media or the internet (Do not
let yourself be trolled).
● Do not share or post anything that may be detrimental to the Company’s business and/or its
reputation.
● Refrain from engaging in discussions outside your area of expertise.
● Rectify or remove any false or misleading information or content about the Company, if You can
not rectify such content please alert the Corporate Affairs team.

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 With regard to speaker engagements, refrain from giving statements and remarks on behalf of the
Company to the press, other forms of mass media, or any private sector or public sector organization
without prior valid authorization from Corporate Communication and/or Corporate Affairs. Prior to
accepting an invitation or any public speaking engagement representing the Company, always seek
valid authorization from Corporate Communication and/or Corporate Affairs.

3. Personal Data Protection and Privacy

Personal Data (hereinafter, “Personal Data”) refers to any information or data , whether true or not,
about an individual who can be identified from that data, or from that data and other information to
which GoTo has or is likely to have access. For the avoidance of doubt, Personal Data may include
personal information on our users, Company Personnel or even potential employees, as well as
related third parties.

In the course of the Company’s business, we collect, process and store Personal Data from data
subjects and Company Personnel from multiple legal jurisdictions. Company Personnel are required
to handle this data with due care and in accordance with applicable laws and regulations, as well as
the Company’s policies and procedures.

To ensure the adequate protection of Personal Data, full compliance is required in regards to the
following:
● Company Personnel are required to ensure that any activities within the Company related to
Personal Data including but not limited to its collection, processing or transfer comply with
applicable laws and regulations as well as internal Company policies.
● All activities related to Personal Data shall be conducted in accordance with data protection
principles and based on valid, informed and freely given consent from the relevant data subjects.
● Personal Data of a sensitive nature, such as but not limited to health data, financial information
and religious and political affiliations are subject to stricter requirements both at the regulatory
and internal policy level, which must be complied with at all times.
● Any use of Personal Data shall be consistent with the specific purpose it was consented to upon
collection and shall be limited to the minimum, as necessary, to fulfill the specific purpose.
● The protection of Personal Data, its integrity and confidentiality from unauthorized access,
modification, loss or inadvertent disclosure shall make use of the appropriate structural and
technical measures available to the Company.
● Company Personnel are required to report any potential loss, misuse or unauthorized use of
Personal Data to the Data Protection Officer team, expediently and without delay upon becoming
aware of such occurrence.

IV. Protecting Company Assets

Company Personnel have the responsibility to use and protect Company assets (tangible or intangible)
and resources. Our ability to protect and conserve Company resources, information and ideas help our
Company to move fast,keep innovating, and create real value for our users

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1. Intellectual Property
The Company’s intellectual property rights, including but not limited to, patents, trademarks, industrial
design, regulatory data, copyrights, trade secrets, “know-how”, domain names, logo and related rights
are among our most valuable assets that are protected under applicable intellectual property laws.
Unauthorized use of such rights may lead to certain loss and/or damages to the Company.

In order to protect the Company’s intellectual property all Company Personnel must, at all times:
● Safeguard and protect the Company’s intellectual property rights at all times.
● Comply with applicable laws and regulations, as well as Company policies regarding intellectual
property. where our business is established and operationalized.
● Report any suspected misuse of the Company’s intellectual property to the whistleblowing email:
ethics@gotocompany.com.
● Respect the intellectual property rights of others. Inappropriate use of others’ intellectual property
may expose the Company and the involved personnel to civil and criminal sanctions. In this
matter, Company Personnel is advised to seek advice from the appropriate Company function
prior to soliciting, accepting or using proprietary information from others or letting others use or
have access to Company’s proprietary information.

2. Company Property
All Company Personnel must care for and maintain the Company’s physical and electronic assets
(hereinafter, “Company Property”). For the avoidance of doubt, Company Property includes but is
not limited to the physical space where You work, the equipment and office supplies, and the data
resources You access. Any Software, hardware, e-mail, computer files, content and programs You
create, receive, send or store are also considered Company Property.

In line with applicable laws and regulations, the Company reserves the right to monitor the use of
Company Property in the course of Company Business and when there is a specific requirement,
such as but not limited to protecting Company Personnel and users, maintaining the security of
resources and other property, or investigating suspected misconduct by Company Personnel.

Company Property must always be strictly used for their designated purpose in the course of
Company Business. Company Personnel are responsible for ensuring that Company Property
entrusted to them is used appropriately and securely.

V. Ensure Financial Integrity and Responsibility

Our Company honors the practice of appropriateness, transparency, and accuracy in all of its business
dealings. All expenditures made by the Company are accurately reflected in the Company’s financial
records and all payments made with Company funds, or on behalf of the Company, have been properly
authorized.

Company Personnel must follow all applicable standards, principles, laws and practices for financials
recording and reporting. Company Personnel must be timely and thorough when preparing all the

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financial records and reports required by the appropriate Company function. In particular, Company
Personnel should ensure that no part of any payment is to be made for any purpose other than as fully
and accurately described in the Company’s books and records. Company Personnel should use best
efforts to ensure that all transactions, dispositions, and payments involving Company funds or assets are
properly and accurately recorded in the Company’s financial records. No undisclosed or unrecorded
accounts are to be established for fraudulent purposes. Personal funds must not be used to accomplish
what is otherwise prohibited by the Code.

VI. Obey the Law

We are committed to conducting all aspects of our business in line with the highest legal standards. Our
Company, including its affiliates, takes its responsibilities to comply with the prevailing laws and
regulations very seriously and each Company Personnel including its affiliates is expected to understand
and comply with the provisions set herein and applicable legal requirements and prohibitions. While it is
impossible for anyone to know all aspects of every applicable law, You as Company Personnel should
understand the major laws and regulations that apply to your work. A few specific provisions of applicable
laws and regulations are prone to unintentional violation and so are worth pointing out here:

1. Anti Bribery & Anti Corruption

Not only is bribery unethical and against the Company’s principles, policies and standards, it may also
expose the Company, as well as Company Personnel to the risk of prosecution, fines and other
penalties, reputational damage, as well as increasing the cost of doing business. We have a strict
“zero tolerance” policy towards bribery and corruption by anyone involved in our business. Our stance
is that it is better not to do business at all than to engage in corrupt or unlawful business. You as
Company Personnel, including your affiliates, must conduct your work activities in full compliance with
all applicable anti-bribery and anti-corruption laws, including the relevant Company anti-bribery and
anti-corruption policies and procedures.

A. Anti-Bribery, Kickbacks, and Facilitation Payments

Company Personnel, including their affiliates, must not offer, promise, pay, solicit, receive or
accept any bribe, kickback, facilitation payment, or other improper payment for any reason
whatsoever. The direct or indirect offer, promise, payment, solicitation or acceptance of such
improper payments in any form by Company Personnel and/or their affiliates, is unacceptable.

B. Gifts, Meals, and Entertainment

As a general matter, the Company competes for and gets business through the quality of its
products and services, and the capabilities of its personnel, rather than through gifts, meals, or
entertainment to its customers or other persons.

The provision of gifts, gratuities, or other favors to any individual or entity (in the private or public
sector, including Government Officials) that has the potential effect of directing business to, or
retaining business for the Company, its affiliates or other persons is generally prohibited.

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 However, gifts of modest or insignificant value that meet certain conditions may be allowed, on
the basis that such gifts are unlikely to have any improper effect.

Common sense and moderation should prevail in business entertainment (and in incurring travel
and lodging expenses while on Company business). Company Personnel may incur
entertainment expenses only if the entertainment is infrequent, modest and is not intended to help
the Company secure an illegitimate advantage. Meals, entertainment, travel and lodging must
never be offered as a means of influencing another person’s business decisions. Such expenses
can be incurred only if it is appropriate and reasonably proportionate to the business relationship
and offered transparently in the course of that business relationship. The primary purpose of
having the meal, entertainment outing or trip must be in the context of relevant business and build
cordial business relations.

C. Employment and Internships

On occasion, Government Officials or business partners of the Company may request that the
Company consider giving internships or employment to certain individuals. An internship of
employment is an item of value and thus, the offer of employment or of an internship to any
person who is related to a Government Official or to a business partner of the Company may
potentially be viewed as a bribe offered to the Government Official or the business partner of the
Company (as the case may be).

As a general matter, the Company will award employment and internships on the basis of
qualification and merit only. In any situation involving a potential candidate who is related to any
Government Official or business partner of the Company, the Company must conduct certain
measures to determine and document the appropriateness of the hiring.

D. Political Contributions and Charitable Donations

Company Personnel may not make political contributions or charitable donations, whether in their
own name or in the name of the Company, if this is aimed at obtaining or retaining business or at
gaining a business advantage.

E. Sponsorship

Any sponsorship in the Company’s name can only be made in accordance with the policy and
procedure of the Company. Company Personnel must never contact users, customers, suppliers
or other business-related contacts to seek sponsorship in a personal or non-work capacity, unless
explicitly pre-approved in writing by the appropriate Company function.

F. Relationships with Third Parties

Third parties represent a key risk area for bribery and corruption. Anti-corruption laws prohibit
both bribes offered or given directly by a person, as well as bribes offered or given indirectly
through a third party acting for or on behalf of the person. Therefore, Company Personnel must
avoid situations involving any third party where a bribe could be made through that third party.

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2. Anti Money Laundering & Combating the Financing of
Terrorism
Our Company is committed to fully comply with Anti-Money Laundering and Combating The
Financing of Terrorism laws and regulations in conducting its business operations. The Company has
policies and procedures in place to safeguard the institution’s fund are used solely for their intended
purposes and not diverted for such uses as laundering money or financing terrorism for any kind of
criminal activities, and take the necessary actions required to prevent, detect and report to the
relevant authorities within the framework of applicable laws.

Company Personnel as well as its affiliated parties are prohibited from participating in or facilitating
money laundering or financing of terrorism. Any Company Personnel involved in money laundering
and/or financing of terrorism activities, even if unintended, may be subject to civil and criminal
sanctions against such person and the Company.

3. Related Party Transaction

In principle, any transaction carried out by the Company involving related parties shall be conducted
in accordance with the applicable laws and regulations, including but not limited to the rules issued by
the Financial Services Authority of Indonesia (Otoritas Jasa Keuangan), as applicable.

When the Company intends to enter into a transaction with related parties, any information related
with such transaction shall be disclosed to the appropriate Company function to be reviewed and
resolved. For further detailed provisions, kindly refer to the relevant policy regarding related party
transactions.

4. Insider Trading
In principle, the Company encourages its Company Personnel to invest in and hold securities
(including shares or bonds) which are issued by the Company, as a long term and non speculative
investment. However, these investments must be carried out in accordance with the applicable capital
market laws and regulations.

As a general matter, Company Personnel including its affiliates are prohibited from trading securities
based on Confidential Information and/or material information of the Company that has not been
officially published or is not nor has not been considered public information.

Company Personnel including its affiliates who have access to confidential information and/or
material information are not permitted to use or share that information for securities trading purposes
or for any other purpose except the conduct of the Company's business.

For the purpose of insider trading, material information means important and relevant information that
may affect the securities price of the Company and/or decision of the investor to purchase or sell
securities of the Company.

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5. Anti Trust and Competition
Our Company conducts business fairly and honestly in compliance with all applicable antitrust and
competition, as well as other applicable laws and regulations which promote fair and open
competition. Our Company strives to keep integrity in all of its business arrangements and
relationships.

In principle, the guideline on antitrust and competition seeks to prevent the Company from violating
competition rules which aims to uphold the efficiency of the market mechanisms. The guideline aim
to:
● Prevent the Company from forming cartels or monopolies and from abusing a dominant market
position.
● Ensure that mergers and acquisitions are subject to proper scrutiny and comply with the rules,
like submitting an acquisitions notification report in a timely manner.
● Ensure the Company does not perform any discriminatory practices in which the Company
imposes a different treatment to a particular party (e.g. to the Company’s driver-partner), without
justified reason for imposing such discriminatory practice, and the discriminatory practice harms
competition or consumers.

These anti-competitive practices often limit competition and take away incentives to innovate, reduce
prices, improve consumer surplus, and create welfare for our partners (e.g. driver-partner and/or
merchant-partner). Anti-competitive practices may also act as trade barriers that enforce exclusivity
towards the competitors and vanishing the competition.

To adhere to the guideline, it is important to seek advice and guidance from the appropriate Company
function, wherever and whenever we encounter a particular situation that may raise antitrust and/or
competition matters.

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