Issue date
October 2026
Supplier Competition Law Policy
Who does this Standard of Conduct apply to?
Applies to all suppliers of Loblaw Companies Limited and its Canadian subsidiaries (collectively “Loblaw”).
1.0 What is this standard about?
This Supplier Competition Law Policy (the “Policy”) outlines the standards of conduct from a competition law perspective applicable to Loblaw’s suppliers. The Policy must be followed by all such suppliers when dealing with us, including when sharing, discussing, accessing, using or disclosing information, and with respect to any Loblaw information such suppliers may receive in the course of our business dealings, including with respect to pricing, costing, volumes, assortment, planograms, recipes, formulas, innovation, contracts and preferred arrangements.
2.0 Why your conduct matters
Compliance with competition law is a priority for Loblaw. Loblaw maintains a Competition Law Compliance Program (“Compliance Program”), and this Policy is an important component of it, to help minimize risk of non-compliance with competition laws.
In particular, competition law prohibits competitors from agreeing to fix prices, allocate markets, or to restrict supply, and prohibits employers from agreeing to fix wages or to not solicit or hire each other’s employees. Information sharing between a supplier and retailer can generate competition law risk if improper information is used, shared, accessed or discussed in your business dealings with Loblaw.
All suppliers and their personnel who engage with Loblaw must comply in full with all applicable competition laws including the Competition Act and adhere to the supplier obligations under the Compliance Program (including this Policy), as provided to you by Loblaw and as may be amended from time to time. The Compliance Program sets out our expectations of how suppliers and their personnel must deal with Loblaw.
Violations of applicable competition law requirements can create legal and reputational risks for both Loblaw and our suppliers. As a result, your adherence to this Policy protects you as well as Loblaw and its colleagues from serious consequences of non-compliance.
3.0 Your responsibility
Suppliers and all of their personnel that transact with Loblaw are responsible for being aware of and complying with this Policy. This includes, but is not limited to, the following obligations:
Advise all supplier personnel, on an ongoing basis, about this Policy before they engage with any Loblaw colleagues;
Ensure your personnel understand and acknowledge the terms of this Policy; and
Seek clarification from your Loblaw Representative, as required.
This Policy is available on our Supplier Portal.
4.0 Your conduct when communicating with Loblaw
4.1 Suppliers must ensure that they and their personnel are aware of and comply with all provisions of the Competition Act in all of their interactions and communications with Loblaw.
4.2 Suppliers MUST NOT provide, or offer to share with Loblaw, another retailer’s or another supplier’s non-public, confidential, commercially sensitive or proprietary business information.
This would include but is not limited to, non-public (i.e., future) retail pricing, costs, proposal or acceptance of cost increases, terms of supply, promotional plans, sales plans or strategies, business plans or strategies, production or sales volumes, forecasts, trade secrets, discounts, payment terms, customers, terms of sale, market shares, advertising restrictions, market allocation, marketing plans, supplier relationships, or levels of output.
When presenting a cost change to Loblaw, Suppliers must not provide Loblaw with information about who has been presented with a cost change or whether competitors or “the market” have accepted a cost change. Suppliers may share cost increase letters with Loblaw that are addressed to customers generally.
4.3 Suppliers MUST NOT discuss with or request from Loblaw non-public (i.e., future) retail pricing information or ask Loblaw to respond to any suggested retail prices supplier may provide.
4.4 Suppliers may suggest a Manufacturer Suggested Retail Price (“MSRP”) or Feature Suggested Price (“FSP”). However, all retail pricing decisions remain within Loblaw’s sole discretion and Loblaw will not confirm its non-public (i.e., future) retail prices.
4.5 Suppliers must adhere to ALL of the following conditions if a supplier provides Loblaw with information and analysis about current and historical retail activity of Loblaw and other retailers, and makes recommendations to Loblaw based on such information:
a) Loblaw must specifically request such information or it’s offered by you to Loblaw and Loblaw specifically agrees to receive such information;
b) It is based on publicly available data or data that is lawfully purchased but does not contain confidential information of another retailer; AND
c) It is submitted to Loblaw in writing.
d) Further, any discussions that take place remain subject to the standards outlined in this Policy.
In the absence of the foregoing, you must not discuss such information with Loblaw nor present such information to Loblaw.
4.6 Loblaw may share non-public (i.e., future) confidential information about its products and services as needed with those suppliers developing products or services for Loblaw. Where Loblaw product and service information is shared with a supplier, the supplier must ensure that such information is kept confidential and sign a Loblaw NDA prior to information being shared.
4.7 Suppliers MUST treat Loblaw confidential information in accordance with the requirements of any confidentiality agreements between the parties, including but not limited to, Loblaw’s standard Supplier Terms and Conditions (“STC”) and/or a Loblaw NDA. Even where a Loblaw NDA or other agreement is not yet signed, suppliers MUST NOT share Loblaw’s non-public, confidential, commercially sensitive or proprietary business information with any third party including, without limitation, any other retailer or supplier, or any franchisee of Loblaw.
4.8 Franchisees of Loblaw, including Associate-owners of Shoppers Drug Mart pharmacies, are competitors of one another and of Loblaw corporate-owned stores. As such, franchisees own and operate their businesses independently. Suppliers MUST NOT share any non-public, confidential, commercially sensitive or proprietary business information of a Loblaw franchisee with Loblaw or any other Loblaw franchisee.
4.9 Suppliers that have a direct sales channel to consumers (e.g., a brick & mortar or e-commerce retail operation that sells the same products you sell to Loblaw) must not discuss the supplier’s non-public (i.e., future) commercial retail plans or strategies with Loblaw. Communication with Loblaw must be through your dedicated team (e.g., sales, supply chain, marketing) and not through the personnel responsible for your retail operations.
4.10 Suppliers’ personnel that have been appointed as Loblaw Vendor Advisors must sign a Loblaw NDA and comply with this Policy.
4.11 In accordance with Loblaw’s internal IT policies, Loblaw colleagues do not use texting, instant messaging or other social media outlets for work purposes. Accordingly, suppliers should only communicate with Loblaw colleagues for work purposes through company email, phone or via in-person conversations.
5.0 The bottom line
Failure to comply with this Policy may adversely impact a supplier’s continuing business with Loblaw, up to and including removal of the supplier’s personnel from the respective Loblaw account and/or discontinuation of the supplier relationship. Where suppliers fail to adhere to this Policy, issues will be reported to Loblaw’s Compliance Program incident management reporting mechanism.
5.1 Loblaw has a defined incident management and escalation process to deal with incidents of non-compliance with this Policy and violations of applicable competition laws.
5.2 Incidents will be monitored, suppliers/supplier personnel will be notified of any non-compliance, and the supplier shall remediate the breach by taking appropriate actions to prevent future breaches. Failure by the supplier to promptly remediate breaches will trigger escalation of the incident, dependent on the nature and frequency of current and past incidents. Corrective action may include, without limitation, written warnings and/or potential review of the supplier relationship.
6.0 What other documents should I look at?
Suppliers must comply with this Policy as well as observe their own company’s antitrust or competition law compliance standards. Suppliers must proactively address differences between their compliance standards and Loblaw’s Compliance Program by coming to an agreement on how to resolve such issues with the Loblaw Sourcing Lead. We expect suppliers to uphold the same values and principles of business conduct as Loblaw does, including as they relate to ethical and safety standards.
Available on Supplier Portal:
Loblaw Policies for National Brand Suppliers
Shoppers Drug Mart Policies for National Brand Suppliers
LCL Policies for Control Brand Suppliers
Loblaw Supplier Code of Conduct
7.0 Questions
If you have any questions, need clarity or have feedback with respect to this Policy, please reach out to your primary Loblaw contact.
Suppliers should consult with their own legal counsel about any questions of competition law and follow their advice. By supplying this Policy, Loblaw is not providing legal advice or establishing any solicitor-client relationship with you.
8.0 Reporting
All suppliers are required to report any non-compliance with this Policy and with the Competition Act. If you have knowledge of, or suspect unethical practices or conduct, speak up by reporting to the Integrity Action Line (1-800-525-7868 or www.integrityactionline.com(Open in a new tab)).
