Team Price Real Estate Brokerage Antitrust Policy

1. PURPOSE

This policy aims to prevent anti-competitive conduct by Team Price Real Estate (TREC LICENSE 9002770) and to reduce even the appearance of such conduct. Non-compliance with this policy may result in disciplinary action, termination, or legal penalties.

2. EFFECTIVE DATE

This policy is adopted and effective as of June 1, 2024, by Team Price Real Estate (TREC LICENSE 9002770). The policy will be reviewed annually and revised as necessary to comply with current laws and best practices.

3. APPLICABILITY

This policy applies to all contractors and staff of Team Price Real Estate (TREC LICENSE 9002770) while conducting business on behalf of the company, including electronic communications and social media interactions. For the purposes of this document, "Team Price Real Estate personnel" refers to all such contractors and staff.

4. GENERAL PRINCIPLES

4.1 Compliance with Laws

Team Price Real Estate is committed to compliance with all applicable federal and state antitrust and competition laws. Regular training will be provided to ensure all personnel are aware of antitrust laws and this policy.

4.2 Increasing Competition

Team Price Real Estate's activities will enhance competition in the markets where it conducts business. Ethical business practices that foster fair competition are encouraged.

4.3 No Collective Action

Team Price Real Estate personnel must never discuss business practices outside the company and must avoid any actions that could give the appearance of collective action plans that could harm consumers or competition. Specific examples of collective action will be provided to prevent misunderstandings.

4.4 Independent Business Decisions

Team Price Real Estate makes independent business decisions on important issues, such as fees, offers of compensation, bidding decisions, and terms of engagement with customers, suppliers, or sales platforms. Team Price Real Estate personnel must never consult with other brokerages on these issues unless advised to do so by the company's legal counsel. Personnel are encouraged to consult legal counsel before making significant business decisions that might raise antitrust concerns.

5. DISCUSSIONS IN ALL MEETINGS AND SOCIAL CONTEXTS

5.1 Prohibited Conduct

In any meeting or social gathering among individuals from different brokerages and in all meetings related to Team Price Real Estate, the following guidelines apply to discussions. Although this list of "dos" and "don'ts" cannot cover everything, the following conduct should never be engaged in without review by Team Price Real Estate’s lawyer:

• An agreement (or activity that might look like an agreement) to fix prices, limit product or service offerings, or divide geographical territory or customers.
• An agreement (or activity that might look like an agreement) to refuse to deal with any third party or parties, including vendors, suppliers, competitors, or customers.
• An agreement (or activity that might look like an agreement) to limit innovation, product choices, or research relating to any of the matters above.
• Sharing recent, current, or planned fee structures, or data regarding business costs, especially if those costs affect service prices.
• Any suggestion that Team Price Real Estate or its personnel will act together with another entity to force a vendor or service provider to change its business models, prices, or service offerings.
• Specific examples of prohibited discussions include sharing future business plans or strategies.

5.2 Obligation to Withdraw and Report

Anyone observing a violation of the above requirements should immediately object, stop the discussion, conspicuously withdraw from the group if the discussion continues, and report the conduct to Team Price Real Estate’s lawyer. Silence is not sufficient. Protections are in place for those who report violations, including anonymity and protection from retaliation.

6. PROCEDURES FOR INDUSTRY MEETINGS

6.1 Team Price Real Estate Meeting Procedures

The following procedures apply to all industry meetings where Team Price Real Estate is involved. An industry meeting is one where representatives of other brokerage firms are expected to be present. Any Team Price Real Estate personnel scheduling, presiding over, or leading such a meeting must ensure the following steps are taken:

• Before the meeting, publish notice of the meeting to those allowed to attend and include an agenda identifying the business that attendees may discuss.
• All Team Price Real Estate personnel receiving the notice and agenda should review it to identify any items that might raise concerns under this policy and refer such items to the sponsor's legal counsel or Team Price Real Estate’s lawyer for review.
• At the beginning of the meeting, attendees should adopt the published agenda and follow it strictly.
• If a discussion is, or is likely to become, inconsistent with this policy, suspend the discussion until it can be reviewed by legal counsel. The minutes should note the suspension.
• Make minutes of meetings, circulate them, and have attendees review them for accuracy before finalizing.

Additionally, a designated compliance officer or legal counsel should be present at all industry meetings. A brief training or refresher on antitrust laws and this policy should be conducted before industry meetings.

7. AVOIDING GROUP BOYCOTTS/CONCERTED REFUSALS TO DEAL

7.1 Group Boycott Prohibited

The real estate industry is unique because competitors often cooperate to serve their customers. This can lead to potential or apparent antitrust violations. A concerted refusal to deal, or group boycott, is an agreement among competitors to refuse to do business with another firm. This is almost always illegal and can result in significant financial damages and criminal charges. Detail the potential legal and financial repercussions of participating in a group boycott.

7.2 Guidelines for Avoiding Group Boycotts

To reduce the chance of being accused of a group boycott, adhere to the following guidelines:

• Do not discuss joining forces with a competitor to change a third company’s business practice.
• Respond to inappropriate actions by competitors, suppliers, or customers in a measured and informed way, avoiding emotional responses. Emphasize the importance of independent responses to competitors’ actions, avoiding any appearance of collusion.

7.3 Guidelines for Compliant Business Practices

Adopt procedures that comply with the following guidelines to reduce the chance of being accused of a group boycott:

• Do not communicate externally about the business practices of another company. Internally, speak with colleagues but be cautious, as internal communications can be discoverable in investigations or litigation.
• You may speak directly to a competitor or business that you believe is behaving inappropriately and explain your concerns, but under no circumstances should you suggest that Team Price Real Estate or others will join together to address the issue. Document all communications with competitors regarding business practices to provide evidence of compliance.

Any questions about the Antitrust Policy should be directed to:

Team Price Real Estate (TREC LICENSE 9002770)
Daniel Staude Price, Broker (TREC License 0525062)
Email: dan@teamprice.com
Phone: 512-963-3768

Preliminary Representation Documents

1.1 REPRESENTATION AGREEMENTS

1.1.1 Policy

All representations of buyers, sellers, landlords, and tenants must be evidenced by a signed written agreement that: (i) describes the terms and conditions of the representation, (ii) details the commission, fees, reimbursements, and costs to be paid to the Broker, and (iii) designates the responsible party for such payments. Ensure that clients fully understand the terms of representation agreements and provide clear, plain language explanations where necessary.

1.1.2 Procedure

a. Seller or Landlord Representation

Representation agreements with sellers and landlords must be signed using a listing agreement approved by the Broker. The agreement must be signed prior to:

• Offering or advertising the property for sale or lease.
• Entering the listing in a multiple listing service (MLS).
• Placing a sign on the property.
• Scheduling or allowing a property showing.
• Preparing or negotiating a sales or rental agreement.
• Allow for the use of electronic signatures and digital documentation to streamline processes.

b. Buyer or Tenant Representation

Representation agreements with buyers and tenants must be signed using a buyer or tenant representation agreement approved by the Broker. The agreement must be signed prior to:

• Showing a property for potential purchase or lease.
• Preparing or negotiating a purchase or rental agreement.
• Allow for the use of electronic signatures and digital documentation to streamline processes.

c. Indirect Seller or Landlord Representation (Subagency)

Representation of sellers or landlords through subagency is documented by the terms of: (i) the listing agreement between the seller and seller's broker, and (ii) the MLS participation agreement. If subagency is permitted, the Sales Associate must confirm:

• That both required documents are in place and effective for the proposed transaction.
• The amount of commission payable under the subagency.
• Representation of sellers or landlords through subagency is:
• Prohibited.
• Permissible only after confirming subagency details.
• Permissible only with the Broker's written consent on a case-by-case basis.

1.2 INFORMATION ABOUT BROKERAGE SERVICES (IABS)

1.2.1 Policy

The mandatory Information About Brokerage Services (IABS) form must be delivered to a party at the first substantive communication regarding specific real property, in accordance with Section 1101.558 of the Texas Real Estate License Act and TREC Rule 531.20, unless the party is represented by another license holder. Ensure consistent delivery of the IABS form in all communications, including electronic and written.

1.2.2 Procedure

Efforts must be made to obtain the party's signature acknowledging receipt of the IABS. If the signature cannot be obtained, the Sales Associate must document:

• The date, place, and circumstances of the IABS delivery.
• The refusal of the client or unrepresented party to sign acknowledging receipt.
• A copy of the delivered IABS must be included with the documentation.
• Implement a follow-up procedure to confirm receipt of the IABS form and address any questions or concerns the client might have.