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Global Competition & Antitrust Policy

Clinicians Check Global Group

Effective Date: 28/05/2025

Version: 1.2

Owner: Legal & Compliance Division

1. Purpose

CliniciansCheck is committed to operating in full compliance with global competition, antitrust, and fair market access laws. This policy ensures that all platform operations, agreements, and collaborations promote healthy competition, prohibit collusion, and prevent abuse of market power across every jurisdiction in which we operate or influence digital health markets.

2. Scope

This policy applies to:

  • All employees, executives, and contractors;

  • All platform users, sellers, sponsors, and partners;

  • All vendors, agencies, affiliates, or advisors representing CliniciansCheck;

  • All forms of commercial listing, advertising, ranking, and monetization models.

3. Global Legal Frameworks

CliniciansCheck aligns its operations with the following competition and antitrust frameworks:

  • UK Competition Act 1998 & Enterprise Act 2002

  • US Sherman Act, Clayton Act & FTC Act

  • EU Treaty on the Functioning of the European Union (Articles 101 & 102)

  • Australian Competition and Consumer Act 2010

  • Indian Competition Act 2002

  • Brazilian Competition Law (Law No. 12,529/2011)

  • South African Competition Act

  • Chinese Anti-Monopoly Law

OECD Guidelines on Competition Assessment

UNCTAD Model Law on Competition

4. Prohibited Conduct

4.1 No Price Fixing — No party may agree to fix prices, discounts, or charges with competitors.

4.2 No Market Allocation — Geographic, platform-based, or audience segmentation between competitors is prohibited.

4.3 No Bid Rigging — Coordinating bids or tenders between parties is illegal.

4.4 No Abuse of Dominance — We will not exploit platform control to unfairly restrict access, exclude competitors, or impose unreasonable conditions.

4.5 No Exclusive Dealing — Contractual restrictions that block fair market access are banned unless legally exempted.

5. Platform Ranking & Commercial Neutrality

5.1 Listings and search rankings are determined by transparent, published criteria and not influenced by payment unless explicitly disclosed.

5.2 Sponsored content is clearly labeled and never disguised as neutral search results.

5.3 No seller or advertiser may pay for top-tier rankings outside of published advertising policies.

6. Partner & Vendor Compliance

6.1 All partners must certify that they will not engage in anti-competitive conduct or collusive behavior.

6.2 Procurement and onboarding processes include competition compliance checks.

6.3 Non-compliant vendors may be reported to relevant authorities and removed from the platform.

7. Enforcement & Audit

7.1 Oversight of this policy lies with the Legal & Compliance Division.

7.2 Random audits and internal reviews are conducted to ensure compliance.

7.3 Violations may result in:

  • Immediate account or contract termination;

  • Referral to national or global competition authorities;

  • Legal proceedings and pursuit of damages.

8. Reporting Concerns

To report suspected anti-competitive practices:

operationsteam@clinicianscheck.com

Anonymous reporting available via internal whistleblowing channel.

"A fair market is a healthy market. Integrity in competition builds trust, innovation, and global sustainability."

— Legal & Compliance Division