Highland Ag Solutions, LLC – Antitrust and Competition Policy

General

It is Highland Ag Solutions, LLC's (“Highland”) belief that competition and the free market is the fairest and most efficient type of economic behavior. Highland is dedicated to these principles. Any activity that intentionally or unintentionally reduces competition or unreasonably restrains trade is contrary to that belief and our policies.

Highland is committed to antitrust compliance and expects the same from its employees and its clients. We deal fairly with clients, suppliers, competitors, employees and agents of Highland.

We will not, and our clients agree that they will not, enter into any agreement with a competitor regarding prices, costs, terms, markets, inventories or any other matter that could affect competition. This policy requires the avoidance of any conduct that violates, or that might appear to violate, the antitrust laws.

Management Responsibilities

It is Highland's intent to comply fully with antitrust laws in the conduct of its business.

Management responsibilities include the following:

• Highland leadership will periodically review this policy with Highland management and client-facing personnel.
• Highland leadership will ensure that this policy is incorporated into its Employee Handbook and otherwise displayed where it will remind management and employees of the importance of antitrust compliance, including the Highland website and physical offices.
• Highland leadership will ensure that this policy is incorporated into its client agreements.

Meeting Antitrust Requirements

Highland clients shall comply with the following requirements when accessing, reviewing, or using Highland's products or services.

• Do not communicate with competitors about current or future prices.
• Do not communicate with competitors about any increase or decrease in prices.
• Do not communicate with competitors about pricing procedures.
• Do not communicate with competitors about standardizing or stabilizing prices.
• Do not ask competitors why a past bid or sale was so low or so high, or to describe the basis for a past bid or sale.
• Do not communicate with competitors about what is a fair profit level.
• Do not communicate with competitors about controlling sales or allocating geographic, product or other markets for any product.
• Do not communicate with competitors about future marketing strategies.
• Do not communicate with competitors about allocating customers.

Highland employees shall comply with the foregoing requirements as it pertains to communicating with one client about any of another client's competitive information.

Please contact Highland leadership to raise any questions about these requirements or this policy, or to report any concern about a potential violation of this policy, for discussion with legal counsel for antitrust matters.