Industry conferences, trade shows, and association meetings sit in a tricky spot for ethics and compliance leaders. These events are valuable, but they are also one of the few places where competitor-to-competitor contact can happen casually, repeatedly, and with limited visibility.
On a recent episode of Ethicast’s BELA Asks, Erica Salmon Byrne, Executive Chair of the Business Ethics Leadership Alliance, notes that effective anti-collusion monitoring starts with risk clarity, not attendance tracking. The goal is a control system that spots real competition-law risk without turning every event into a paperwork storm.
What is the competition-law risk you are actually trying to manage?
The first step is naming your risk in plain terms. “Antitrust” can mean very different things depending on your industry, market position, and how your commercial teams operate.
Erica flags several risk patterns that show up around competitor interactions, including:
- Price coordination and pricing-related “signals”
- Market allocation, formal or informal (“you take these accounts, we take those”)
- Supplier pressure or coordinated “blackballing”
- Hiring and talent discussions that drift into improper territory
- Algorithmic collusion, where shared tools and market data make coordination easier to slip into
That list is the starting map. Your program’s work is deciding which of these risks is plausible for your business right now, and where the business is most exposed.
How do you translate risk into a workable monitoring plan?
Monitoring plans fail when they sit at the wrong altitude. If they are too abstract, then nobody knows what to do. But if they’re too in the weeds, then the business will route around it.
A workable plan ties together three elements:
- Event triggers: what types of gatherings matter, and why
- Role triggers: which employees create exposure when they attend
- Conversation triggers: what topics and situations require immediate caution and escalation
The decision point for E&C leaders is defining triggers that the business can recognize quickly. That is what makes monitoring possible in real life, especially when your team cannot physically attend every gathering.
Which gatherings deserve extra scrutiny?
The structure of the event matters as much as the attendee list. Erica calls out practical risk indicators that are easy to miss if the review process only checks “industry event” as a category.
Higher-risk features can include:
- Closed-door sessions with limited attendance
- Small peer groups where side conversations are the main point
- Agenda gaps that create lots of unsupervised time
- Heavy alcohol settings where judgment drops and talk gets loose
- Peer-to-peer networking formats explicitly designed for competitor conversations
This is where your clearance process can mature. You are not trying to judge whether conferences are allowed. You are building a risk lens that distinguishes a large public trade show from an intimate executive roundtable with competitors.
How do you reduce “CYA disclosures” without lowering vigilance?
A common failure point is when employees get just scared enough that they disclose everything to protect themselves. This floods Compliance with noise that burns time, delays approvals, and trains the business to treat compliance as a checkbox instead of a control.
To reduce ambiguity and make the clearance process more specific than “competitors may be present,” consider structuring clearance around:
- Two or three risk questions employees can answer accurately (format, competitors present, closed sessions, social events)
- Role-based routing so high-risk functions get a tighter review and lower-risk roles get faster decisions
- Pre-approved event types for low-risk scenarios, refreshed periodically
- A short escalation path for edge cases that need a fast call with Legal or Compliance
This approach keeps attention on the situations that deserve it, while giving employees permission to stop over-disclosing out of fear.
Who needs training first, and what should that training cover?
Training works when it helps people recognize the moment risk shows up. Prepare your highest-risk employees to spot issues early, so the organization can get in front of problems.
Prioritize training for roles most likely to interact with competitors directly; attend industry gatherings frequently; speak publicly on panels; negotiate commercial terms or manage strategic accounts; and work with pricing, market intelligence, or hiring.
Then make training concrete. Give people:
- A short list of sensitive topics (pricing, markets, supplier boycotts, hiring discussions, coordination through shared tools)
- Examples of “how it starts” in normal conversation
- Simple exit and escalation scripts they can use without making it awkward
- Clear internal contacts for real-time questions when they are on the road
These things help employees build solid judgment under pressure, rather than testing whether someone remembers a policy paragraph.
What does “monitoring during the event” look like when Compliance is not onsite?
Most compliance teams are not staffing trade shows. Monitoring still needs to exist, and it needs to be realistic.
Consider a light structure for higher-risk events:
- Pre-brief: a 10-minute reminder of the risk triggers and escalation channel
- Designated point person: one attendee accountable for watching for risk moments
- Daily check-ins: short calls or messages for multi-day events
- Documented escalations: capture what happened and how it was handled, even if it ended quickly
- Post-event note: a short debrief focused on risk triggers, not travel commentary
This routine makes it easier for employees to surface issues early, before a casual conversation turns into a bigger problem. And, it avoids needless surveillance.
How should you handle the predictable “social risk” moments?
Agendas often include alcohol, which helps people make bad choices. A practical control is identifying, in advance, which social settings are tied to the event (receptions, dinners, hospitality suites) and setting clear expectations:
- keep group conversations in professional territory
- avoid sensitive topics entirely, even if someone else brings them up
- leave quickly if the conversation turns toward pricing, market division, supplier exclusion, or hiring restrictions
- use escalation channels promptly when something feels off
Chances are, your organization already has policies and expectations in place around employee consumption of alcohol during work-related events. This is a perfect opportunity to dovetail with that existing framework.
How does “algorithmic collusion” change what you watch for?
Erica notes that “algorithmic collusion” has entered the vernacular in a way it was not five years ago. Even without an explicit agreement, companies using similar market data tools can drift into patterns that look coordinated.
For monitoring, that changes the questions you ask about conference conversations and follow-up:
- Are teams discussing shared pricing tools, market dashboards, or the “right” price levels?
- Are peers swapping inputs that would shape models (discounting logic, capacity constraints, supply plans)?
- Are employees using competitor chatter to justify “the market is moving this way” decisions without scrutiny?
How often should you refresh your risk assessment for competitor interactions?
Risk assessments go stale fast, especially as market position shifts, new markets open, or the company approaches dominance in a segment. The monitoring program you built five years ago may be calibrated for a company you are no longer running.
Set a cadence to revisit:
- market footprint and competitive dynamics
- which roles create the most exposure
- where you attend events and why
- what “high-risk gathering” means for your current posture
Treat this as program maintenance. It is part of keeping controls aligned to the business you have, not the business you used to have.
For Erica’s full perspective on this topic, you can watch the episode here:
To see how BELA members share questions like this and access practical resources and peer insight, learn more about the Business Ethics Leadership Alliance (BELA).
Bill Coffin | Editor-in-Chief, Ethisphere Magazine, Ethisphere
Bill Coffin is the Editor-in-Chief of Ethisphere Magazine and supports the larger content strategy of Ethisphere. He is an internationally recognized writer and editorial leader in the fields of ethics, compliance, insurance and risk management. His work has appeared in The Wall Street Journal, BusinessWeek, Forbes and Fortune, as well as Compliance Week, National Underwriter, Risk Management, Best’s Review and other B2B media. Previously, Bill served as Director, Senior Editor at AIG, leading content strategy for one of the world’s largest insurance companies.
