Antitrust policy

Why this is published

A trade association does not shelter unlawful coordination. The Federal Trade Commission is explicit on this point, and it applies with particular force to an industry where the members bid against each other for the same freight.

The uncomfortable part is that the risky features are ordinary association features. A member directory, a benchmark report, a discussion forum — each is something members ask for, and each becomes an unlawful information exchange if it carries the wrong fields. There is rarely a moment where someone proposes doing something obviously wrong.

That is why the limits below are database constraints and disabled features rather than a policy document. A policy can be forgotten by someone new working under deadline pressure. A constraint cannot.

Information this platform will never carry

No member-visible surface — directory, benchmark, offer listing, support thread — carries any of the following about another member:

• Current or future freight rates
• Customer-specific pricing
• Bids, margins, or costs
• Capacity commitments
• Market or customer allocation
• Driver pay or wage coordination
• Fuel surcharge coordination

Features we have deliberately not built

These are switched off in code, not merely absent from the roadmap. Turning any of them on is a decision the board and counsel have to make together and sign for.

Association-wide forum and member-to-member messaging

The most common way a benign association feature becomes an information exchange. If it is ever enabled it will ship with terms acceptance before posting, automatic quarantine of flagged content, and a compliance case for counsel to review — not on its own.

Deal boards and member-posted rate or capacity listings

Not built, and not planned.

Salary and compensation surveys

Not without counsel approval of the questions themselves, because the wording determines whether the result is a benchmark or a wage signal.

If we ever publish benchmarks

Aggregated industry data is genuinely useful, and it is also the easiest way to arrive at an unlawful exchange by accident. If this association publishes benchmarks, every published figure will satisfy all of the following, enforced by the database rather than checked by hand:

At least five independent contributors per published figure

A two-carrier "average" is each carrier's number with an extra step.

No single contributor above 25% of a figure

One dominant contributor makes the aggregate readable as their own number.

Complementary suppression

Hiding one small cell achieves nothing if its value can be recovered by subtracting the published cells from a published total, so both are suppressed together.

Data at least six months old

Historical data informs planning. Current data coordinates behaviour.

Counsel approval before publication, recorded

With the methodology, the contributor count and the suppression record kept as evidence.

Raw submissions are never visible to members and are never joined back to a published figure in any member-facing query.

Positions on divisive issues

The association takes a public position only when the board adopts one by resolution. Until then our published material explains a rule and its operational consequences without advocating an outcome, and "no position" is a legitimate answer we will give plainly.

Some rules genuinely split this membership — one carrier benefits from a change that directly harms another. An association that manufactures consensus in that situation is not representing its members. Where we run member sentiment polls, responses are stored separately from the record of who participated, so the two cannot be rejoined.

Meetings and training

Board and committee agendas require counsel approval before notice goes out, and material added afterwards reopens that approval. Declared conflicts produce recusals that adjust the quorum for that item alone.

Antitrust training is a scored module with an expiry rather than an acknowledgement checkbox — a checkbox is not evidence that anyone understood the policy. Expired training suspends voting privileges until it is completed.