Anti-Trust Policy | Ensuring Fair Business Practices at Labrada Realty LLC
1. Purpose
This Anti-Trust Compliance Policy is designed to ensure that Labrada Realty LLC and its associates, agents, and employees conduct all business practices in accordance with federal and state anti-trust laws, including the Sherman Act, Clayton Act, Federal Trade Commission Act, and Florida Deceptive and Unfair Trade Practices Act. Violations of these laws can lead to severe penalties, including substantial fines, damages, and reputational harm. The purpose of this policy is to maintain a fair, competitive business environment and protect Labrada Realty LLC from the risks associated with anti-trust violations.
2. Scope
This policy applies to all associates, agents, employees, contractors, and any other individuals or entities representing Labrada Realty LLC.
3. Prohibited Activities
All associates, agents, employees, and representatives of Labrada Realty LLC are strictly prohibited from engaging in any anti-competitive behavior, including but not limited to the following activities:
A. Price Fixing
- Definition: An agreement between competitors to fix, control, or establish commission rates, fees, or terms of service.
- Policy: All commission rates and fees must be set independently by each agent. Agents must not engage in discussions with competitors regarding commission rates or any other terms of compensation.
B. Market Allocation
- Definition: An agreement between competitors to divide or allocate markets, territories, clients, or types of services.
- Policy: Associates and agents must not enter into agreements with competitors to divide territories, client types, or limit service offerings in specific areas.
C. Group Boycotts
- Definition: An agreement between two or more competitors to refuse to work with a particular client, supplier, or competing brokerage.
- Policy: Associates and agents must not engage in or agree to any form of group boycott or coordinated refusal to work with other agents, clients, or service providers.
D. Bid-Rigging
- Definition: An agreement between competitors on who will submit the winning bid in a real estate transaction.
- Policy: Agents must not participate in any discussions or agreements with other real estate professionals regarding bidding strategies or outcomes in transactions.
E. Disparagement of Competitors
- Policy: Associates and agents must not disparage or undermine competing brokerages or agents in a manner that restricts fair competition.
4. Guidelines for Conduct and Communication
A. Internal Discussions
- All communications within Labrada Realty LLC must remain professional and free of any language or suggestions that could imply anti-competitive behavior. Agents must not share sensitive business information, such as commission rates or service fees, except with appropriate management personnel as needed.
B. External Discussions
- Agents must not discuss commission rates, market territories, or other sensitive business information with competitors or outside parties. This includes conversations at industry events, training sessions, and informal meetings.
C. Written Agreements
- All agreements with clients and other real estate professionals must be in writing, clear, and free from any language that could be perceived as anti-competitive.
D. Social Media and Marketing
- Associates and agents must exercise caution when using social media or marketing platforms. Avoid making statements that suggest industry-wide standards, fixed pricing, or market allocation.
5. Training and Compliance
Labrada Realty LLC will provide anti-trust compliance training to all associates, agents, and employees upon hiring and on an annual basis. Training will cover:
- Federal and state anti-trust regulations.
- Identification of prohibited behaviors.
- Best practices for compliance.
- Procedures for reporting concerns.
6. Reporting Violations
All associates, agents, and employees of Labrada Realty LLC are required to report any suspected anti-trust violations immediately to the Broker-Owner or designated compliance officer. Reports can be made anonymously if desired. No retaliatory actions will be taken against anyone making a report in good faith.
7. Disciplinary Action
Violations of this policy or anti-trust laws will result in disciplinary action, up to and including termination of employment or association with Labrada Realty LLC. If an agent is found to have violated anti-trust regulations, they may also be subject to legal action, including civil or criminal penalties.
8. Acknowledgment of Anti-Trust Compliance Policy
All associates, agents, and employees of Labrada Realty LLC are required to read, understand, and sign this Anti-Trust Compliance Policy annually, indicating their commitment to adhering to its principles and practices.
Broker-Owner Signature: 
Date: 10/01/2024
