Minimum Advertised Price (MAP) Policy FAQ
ANSWERS TO FREQUENTLY ASKED QUESTIONS ABOUT BERETTA U.S.A.’S MINIMUM ADVERTISED PRICING (MAP) AND MINIMUM TRANSFER PRICING (MTP) POLICIES
- Does Beretta U.S.A.’s MAP policy apply to dealer postings on a website?
Beretta U.S.A.’s MAP pricing applies to any communication (whether on a website, in a flyer, in a catalog, in a magazine or newspaper, through social media, through mailers, etc.) that is intended or has the effect of being seen by more than one person and is not made in response to a request for information by an individual.
- If a dealer advertises a Beretta U.S.A. product at its MAP pricing floor and then also offers a discount on other goods or a rebate with the sale, is that a violation of Beretta U.S.A.’s MAP policy?
Effective January 1, 2023 and thereafter Beretta U.S.A. policy defines MAP violation as advertising the giving of anything of value, even another product, gift, coupon or discount, that is tied to the purchase of the Beretta/Sako/Tikka product if the giving of that additional product, gift, coupon or discount would, in turn, bring the value of the Beretta/Sako/Tikka product below MAP if the items are considered in the aggregate.
- Can MAP be enforced by Beretta U.S.A. against non-direct dealers who buy Beretta products from distributors (not from Beretta U.S.A.) and then advertise the product for sale below MAP?
We have informed our distributors that we expect our products only to be sold (in other words, transferred) by them at or above certain specified prices. At the same time, we have informed our direct dealers that we expect that our products will only be advertised at or above certain prices that we have also set (our Minimum Advertised Pricing Policy). We enforce the policy by acting unilaterally, meaning that if we find out about a violation of either the MAP or MTP pricing policy, we unilaterally enforce the policy by penalizing the offending customer. (In our policies, we do so by suspending shipment of product to them for initial violations, escalating the penalty to complete termination of business if enough violations occur.)
- Is it a MAP Violation if the advertisement implies or suggests a lower price?
An advertisement that states or implies that any of our products covered by this policy will be sold at a price that is less than MAP violates this policy. Advertisements that list, for example, a Beretta product at the MAP price but then also contain phrases such as “click for best price”, “email for best price”, “call for lowest price” or other similar phrases that imply that the price will be adjusted below the MAP price are a violation of this policy. For purposes of internet sales, the entire website including the “shopping cart” or similar website location will be considered part of the advertisement if it can be accessed by links contained on or within the primary website.
- If I report a MAP or MTP violation how can I find out whether Beretta U.S.A. has enforced its policy against the violator?
Beretta U.S.A. investigates any reported MAP and MTP violation brought to its attention. Because this is a wholly unilateral policy, Beretta U.S.A. cannot and will not report back on the status of its MAP or MTP enforcement efforts to those who advise us of potential violations.
- How are Beretta U.S.A.’s MAP or MTP policies the same or different than those of competitors?
Beretta U.S.A. sets its own MAP and MTP policies without consulting with any other company. The terms of Beretta U.S.A.’s MAP and MTP policies are its own only. Any questions about another company’s MAP or MTP policies should be sent to that company and not to Beretta U.S.A.
- What if an employee or media supplier makes a mistake that results in a MAP violation?
It is the Distributor and/or Dealer’s responsibility to monitor its own advertising. Beretta U.S.A. will not differentiate between intentional and accidental violations when enforcing the MAP Policy.
- Does Beretta U.S.A.’s MAP policy apply to in-cart pricing?
As stated in the Beretta U.S.A.’s MAP Policy, prices shown online will be subject to this policy. Online selling procedures (i.e. “add to cart”) cannot advertise or imply that doing so will reduce the price advertised online below MAP.
- Does Beretta U.S.A.’s MAP policy apply to email pricing?
As stated in Beretta U.S.A.’s MAP Policy, prices displayed by a Dealer on any web pages that are less than MAP will result in a violation.
- Does Beretta U.S.A.’s MAP Policy apply to Loyalty Programs?
A customer can use accrued points or other benefits earned as a member of the Dealer’s loyalty program when purchasing Beretta products. However, the advertised retail price of the product before applying any points or benefits must be at, or above, the MAP price.
- Does Beretta U.S.A. ever have MAP Holidays, meaning a date or dates on which MAP is waived or MAP pricing is reduced?
From time to time, Beretta U.S.A., at its sole discretion, may announce MAP Holidays. These MAP Holidays will be communicated in advance to retailers and distributors.
