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COMOS DDMS Pharma Community Participation Guidelines

It is of highest importance for all participants including Siemens to absolutely avoid any violation against law (including, e.g. antitrust law, other relevant compliance fields).

The basic principles of antitrust law are clear and simple: Limit the exchange of information to such information which is required for the purposes of the COMOS DDMS Pharma Community and do not discuss or align on competitively sensitive topics with potential competitors (e.g. strategic information such as prices, markets and customers, innovation plans). For Siemens to succeed in unrestricted and fair competition with its competitors is consistent with both Siemens’ values and with the pioneering spirit of our company.

Through his or her presence, every participant agrees to follow applicable laws (including antitrust regulations) and avoids every action that could cause a conflict for the community. If the participant observes indications for a misuse of the COMOS DDMS Pharma Community for anti-competitive behavior, the participant shall inform a responsible Siemens employee without undue delay.

As part of this COMOS DDMS Pharma community event content that is competitively sensitive will not be discussed between (potential) competitors. This applies to all forms of exchange such as:

  • expressly or implicitly,
  • directly or indirectly,
  • verbally or in writing.

This limitiation is valid for personal or virtual meetings, their preparation or follow-ups. In particular no discussions about:

  • prices or costs,
  • customers or suppliers,
  • capacities,
  • purchasing or selling conditions,
  • bids,
  • R&D or business strategies, roadmaps, investments, intended future market conduct,
  • information related to personnel recruitment,
  • quotas or alike

will take place between companies or persons involved in this COMOS DDMS Pharma community.


The participant shall comply with all applicable sanctions, embargoes and (re-) export control laws and regulations, and, in any event, with those of the European Union, the United States of America and any locally applicable jurisdiction (collectively “Export Regulations”).

Non-Acceptable Use of Software and Cloud Services:

The participant shall not, unless permitted by the Export Regulations or respective governmental licenses or approvals, (i) download, install, access or use the [Services] from or in any location prohibited by or subject to comprehensive sanctions or subject to license requirements according to the Export Regulations; (ii) grant access to, transfer, (re-)export (including any ‘deemed (re-)exports’), or otherwise make available the [Services] to any entity, person, or organization identified on a restricted party list of the Export Regulations, or owned or controlled by a listed party; (iii) use the [Services] for any purpose prohibited by the Export Regulations (e.g. use in connection with armaments, nuclear technology or weapons); (iv) upload to the [Services] platform any customer content unless it is non-controlled (e.g. in the EU: AL = N; in the U.S.: ECCN = N or EAR99); or (v) facilitate any of the aforementioned activities by any user. Customer shall provide all users with all information necessary to ensure compliance with the Export Regulations.