Code of Conduct

THE SPARTAN ALLIANCE

Effective Date: October 1, 2025

Preamble

THE SPARTAN ALLIANCE unites legitimate brands in the fight against counterfeiting. This Code of Conduct ensures all members operate with integrity, respect, and professionalism while maintaining legal compliance and ethical standards.

1. Core Principles

1.1 Unity in Purpose

  • We stand together against counterfeiters
  • Individual success strengthens collective defense
  • Collaboration over competition in brand protection

1.2 Integrity

  • Honest and transparent communication
  • Accurate reporting of threats and incidents
  • No misuse of Alliance resources

1.3 Respect

  • Professional conduct with all members
  • Respect for intellectual property rights
  • Cultural sensitivity in global operations

2. Information Sharing Guidelines

2.1 Appropriate Sharing

DO Share:

  • Counterfeit seller information
  • Fake product identification methods
  • Successful enforcement strategies
  • Emerging threat patterns
  • Bad actor networks

2.2 Prohibited Sharing

DO NOT Share:

  • Pricing information
  • Market allocation plans
  • Customer lists
  • Competitive strategies unrelated to anti-counterfeiting
  • Trade secrets beyond brand protection needs

2.3 Accuracy Standards

  • Verify information before sharing
  • Clearly label unconfirmed intelligence
  • Correct errors promptly
  • No intentionally false or misleading information

3. Competition Law Compliance

3.1 Antitrust Guidelines

Members must NOT:

  • Discuss or coordinate pricing
  • Allocate markets or customers
  • Agree to boycott specific suppliers/customers
  • Share competitively sensitive information
  • Engage in bid-rigging

3.2 Safe Harbor Topics

Acceptable discussions include:

  • Anti-counterfeiting strategies
  • Enforcement best practices
  • Legal precedents
  • Technology solutions for brand protection
  • Public policy advocacy

4. Confidentiality and Security

4.1 Information Classification

  • PUBLIC: Can be shared freely
  • MEMBER CONFIDENTIAL: Within Alliance only
  • RESTRICTED: Need-to-know basis

4.2 Security Practices

  • Use secure communication channels
  • Strong passwords and 2FA required
  • No sharing of login credentials
  • Report security incidents immediately

5. Platform Usage

5.1 Acceptable Use

  • Professional communication
  • Relevant brand protection content
  • Constructive feedback and suggestions
  • Resource sharing for collective benefit

5.2 Prohibited Activities

  • Spam or excessive messaging
  • Harassment or discrimination
  • Malware or hacking attempts
  • Commercial solicitation unrelated to mission
  • Political campaigning

6. Enforcement and Investigations

6.1 Cooperation Standards

  • Respond to legitimate information requests
  • Participate in joint operations when feasible
  • Share enforcement outcomes for learning

6.2 Legal Boundaries

  • Comply with all applicable laws
  • No unauthorized surveillance
  • Respect privacy rights
  • Coordinate with law enforcement appropriately

7. Conflicts of Interest

7.1 Disclosure Requirements

Members must disclose:

  • Business relationships with other members
  • Financial interests affecting objectivity
  • Potential conflicts in joint operations

7.2 Management

  • Recuse from decisions where conflicts exist
  • Transparent handling of conflict situations

8. Data Protection and Privacy

8.1 Personal Data

  • Process only for agreed purposes
  • Comply with GDPR, CCPA, and applicable laws
  • Minimize data collection
  • Secure deletion when no longer needed

8.2 Third-Party Data

  • Respect third-party rights
  • No unauthorized data scraping
  • Proper attribution of sources

9. External Communications

9.1 Public Statements

  • No speaking on behalf of Alliance without authorization
  • Accurate representation of Alliance activities
  • Respect member confidentiality in public forums

9.2 Media Relations

  • Coordinate with Alliance for joint announcements
  • Individual members may discuss own activities
  • No disclosure of confidential operations

10. Reporting Violations

10.1 Reporting Channels

  • Email: [email protected]
  • Anonymous hotline: [To be established]
  • Report to Board members directly

10.2 Whistleblower Protection

  • No retaliation for good faith reports
  • Confidential investigation process
  • Fair and impartial review

11. Disciplinary Actions

11.1 Minor Violations

  • Warning and guidance
  • Additional training if needed
  • Temporary restriction of privileges

11.2 Major Violations

  • Suspension of membership
  • Termination of membership
  • Legal action if warranted
  • Public disclosure in severe cases

12. Compliance Monitoring

12.1 Regular Reviews

  • Annual compliance certification required
  • Periodic audits of platform usage
  • Member feedback surveys

12.2 Continuous Improvement

  • Regular updates based on member input
  • Adaptation to new threats and challenges
  • Best practice sharing

13. Training and Support

13.1 Onboarding

  • Mandatory Code of Conduct training
  • Platform security training
  • Competition law basics

13.2 Ongoing Education

  • Quarterly compliance reminders
  • Updates on legal developments
  • Best practice webinars

14. Amendment Process

  • Annual review by Board
  • Member input period (30 days)
  • Majority vote for changes
  • 30-day notice before implementation

15. Acknowledgment

All members must acknowledge understanding and agreement to comply with this Code of Conduct.

Member Acknowledgment

I have read, understood, and agree to comply with THE SPARTAN ALLIANCE Code of Conduct.

Company: _____________
Representative Name: _____________
Title: _____________
Date: _____________
Signature: _____________

“United We Stand Against Counterfeits”

Contact for Questions:

This Code of Conduct is a living document and will evolve with our Alliance.