never engage in theae activities with competitors

Set prices or create price ceilings or floors
Rig bids
Refuse to deal with third parties
Allocate customers or territories
Set quotas or limits on sales to or purchases from third parties

when working with third parties you must:

Thoroughly evaluate their qualifications and reputations
Ensure that they will comply with our anticorruption policies and applicable laws
Obtain written agreements and contracts approved by our Law Department

Retaining marketing consultants and sales agents requires the written approval of the Chief Complaince Officer and the Gneral Counsel.

when working with third parties you must not:

Make payments other than in return for legitimate products or services provided according to the terms of an
Offer-or accept—a bribe
Engage in excessive entertainment with customers or
suppliers as such situations could be construed as attempts to
obtain improper performance

INTRODUCTION TO WORKING WITH OTHERS

Working with other companies

GATX aims to deal fairly and in good faith with our customers, suppliers, business partners and competitors. Underlying this commitment to integrity is our obligation to comply with all applicable laws wherever we do business.

FAIR DEALING

Taking advantage of anyone through manipulation, abuse of privileged or confidential information, misrepresentation, fraudulent behavior or any other unethical business practice is considered a violation of the Code.

It’s sound business practice for us to obtain information about markets in which we operate, including information about our competitors, their products and services. However, you may accept competitive information only when you believe it has been obtained legally and ethically. You must never seek to acquire a competitor’s trade secrets or other proprietary information through unlawful or unethical means.

Antitrust and Competition

At GATX, we aggressively compete but conduct business only according to the letter and spirit of all laws that govern and promote free and fair competition. All GATX employees must strictly comply with the antitrust laws of the United States and, if you work abroad, the antitrust or related laws the country where you work. Violations of antitrust laws can carry serious consequences.

The antitrust laws are complicated and cannot be completely covered here. If your responsibilities at GATX are subject to antitrust laws, your decisions must be based on our Antitrust Policy and the advice of the Law Department. If you have questions about activities with antitrust implications, be sure to check with the Law Department before taking any action.

Hiring & Working with Third Parties

Hiring and Working with Third Parties

Our company may be liable for the illegal activities of third parties who act on our behalf, even if such activity wasn’t authorized by anyone at GATX. For that reason, it’s critical to exercise due diligence if you’re responsible for hiring consultants, agents or companies or individuals to work on our behalf.

Delegated Authorities

GATX bylaws authorize our officers to make commitments on the company’s behalf. We have detailed guidelines (known as the Delegated Authorities) specifying which officers and employees are authorized to do so. Be sure to check these guidelines before making a commitment on behalf of GATX.