1. Copyright© 2010 WeComply, Inc. All rights reserved. 8/23/2015 EU Competition Law

2. Copyright© 2010 WeComply, Inc. All rights reserved. 8/23/2015 EU Competition Law

3. Copyright© 2010 WeComply, Inc. All rights reserved. 3 Introduction to the European Union Background information on EU institutions: EU consists of 27 Member States EU and three other countries are part of European Economic Area (EEA) EU competition law applies to all countries in the EEA

4. Copyright© 2010 WeComply, Inc. All rights reserved. 4 EU Institutions EU Institutions: European Commission European Parliament Council of Ministers Commission enforces competition policy through directorate general (DG) Can launch surprise investigations at company premises Can require large mergers to be approved EU Member States have their own competition laws and authorities Companies must comply with competition laws of EU and Member States

5. Copyright© 2010 WeComply, Inc. All rights reserved. 5 Enforcement of Competition Law We require strict compliance with laws of any country in which we do business Competition law enforcement is Commission’s top priority DG Competition actively enforces rules in Treaty on the Functioning of the European Union (TFEU) Violators take a huge risk of being investigated and sanctioned Companies must comply with competition laws of EU and Member States

6. Copyright© 2010 WeComply, Inc. All rights reserved. 6 In the news…

7. Copyright© 2010 WeComply, Inc. All rights reserved. 7 Consequences of Non-Compliance Non-compliance has serious consequences: Fines up to 10% of annual worldwide turnover Liability in damages under national law Voiding of contract Criminal liability Substantial expenditure of time and money Bad publicity Investigations by other competition authorities

8. Copyright© 2010 WeComply, Inc. All rights reserved. 8 Consequences of Non-Compliance (cont’d) Non-compliance has serious consequences: Fines up to 10% of annual worldwide turnover Liability in damages under national law Voiding of contract Criminal liability Substantial expenditure of time and money Bad publicity Investigations by other competition authorities

9. Copyright© 2010 WeComply, Inc. All rights reserved. 9 Consequences of Non-Compliance (cont’d) Non-compliance has serious consequences: Fines up to 10% of annual worldwide turnover Liability in damages under national law Voiding of contract Criminal liability Substantial expenditure of time and money Bad publicity Investigations by other competition authorities

10. Copyright© 2010 WeComply, Inc. All rights reserved. 10 Consequences of Non-Compliance (cont’d) Non-compliance has serious consequences: Fines up to 10% of annual worldwide turnover Liability in damages under national law Voiding of contract Criminal liability Substantial expenditure of time and money Bad publicity Investigations by other competition authorities

11. Copyright© 2010 WeComply, Inc. All rights reserved. 11 Overview of EU Competition Law Aspects of primary importance to business: Article 101 TFEU makes illegal any agreement or concerted practice between undertakings that significantly restricts competition within EEA Article 102 TFEU makes it illegal for dominant company to abuse its dominant position in market EU competition law deals with anti-competitive agreements between companies and unilateral conduct of individual companies with dominant position

12. Copyright© 2010 WeComply, Inc. All rights reserved. 12 Overview of EU Competition Law (cont’d) Aspects of primary importance to business: Article 101 TFEU makes illegal any agreement or concerted practice between undertakings that significantly restricts competition within EEA Article 102 TFEU makes it illegal for dominant company to abuse its dominant position in market EU competition law deals with anti-competitive agreements between companies and unilateral conduct of individual companies with dominant position

13. Copyright© 2010 WeComply, Inc. All rights reserved. 13 Article 101 TFEU: Purpose and Rationale Article 101 prohibits agreements that disrupt free-market principles and hinder competitiveness Article 101 promotes independent decision-making over - Pricing Whether to sell in one country or several Decisions should be based on desire to attract new customers and retain existing ones Agreements that restrict two or more companies’ commercial options are likely to violate Article 101

14. Copyright© 2010 WeComply, Inc. All rights reserved. 14 What Is an Anti-Competitive Agreement? For conduct to be prohibited under Article 101(1): There must be agreement, decision or concerted practice Agreement must involve more than one undertaking Agreement must have as its object or effect the restriction of competition Agreement must affect trade between EU Member States If any one element is missing, there is no restriction of competition Agreement where restrictions on competition are outweighed by positive economic effects may be exempt

15. Copyright© 2010 WeComply, Inc. All rights reserved. 15 What Is an Anti-Competitive Agreement? (cont’d) For conduct to be prohibited under Article 101(1): There must be agreement, decision or concerted practice Agreement must involve more than one undertaking Agreement must have as its object or effect the restriction of competition Agreement must affect trade between EU Member States If any one element is missing, there is no restriction of competition Agreement where restrictions on competition are outweighed by positive economic effects may be exempt

16. Copyright© 2010 WeComply, Inc. All rights reserved. 16 Consequences of Article 101 Violation Anti-competitive agreement is legally void and unenforceable Consequences: It can totally disrupt commercial relationships – e.g., where agreement is basis of core business functions It can also attract substantial fines and lawsuits

17. Copyright© 2010 WeComply, Inc. All rights reserved. 17 Recognising "Red Flags" Competition law issues typically arise in these contexts: 1.Relationships with competitors 2.Relationships with customers 3.Relationships with licensees 4.Behavior of a dominant company 5.Internal filing and drafting documents

18. Copyright© 2010 WeComply, Inc. All rights reserved. 18 Relationships with Competitors Relationships with competitors pose highest risk Keep in mind: Be aware of competition laws when speaking or dealing with a competitor Meeting/talking with competitor may raise inference of agreement to restrain competition Competitor contacts receive utmost scrutiny from authorities Inform the Legal Department of any contacts that you are planning to have with competitors

19. Copyright© 2010 WeComply, Inc. All rights reserved. 19 Cartels Cartel: An arrangement between competing firms designed to limit or eliminate competition between them Cartels are harmful because they enable participants to charge higher prices than in competitive market Cartels are most serious infringement of EU competition law Cartel behavior can lead to extremely high fines and criminal sanctions Most common types of cartels are price-fixing, market-sharing, output limitation and bid-rigging

20. Copyright© 2010 WeComply, Inc. All rights reserved. 20 Red Flag: Price-Fixing Agreement between competitors on pricing is almost always illegal Price-fixing is prohibited in both horizontal and vertical relationships Agreement between competitors to set minimum prices is blatant price-fixing Indirect agreements may also be illegal, e.g. to – Compare price lists before publication Exchange detailed information on each other’s production costs Agree on any other term of sale

21. Copyright© 2010 WeComply, Inc. All rights reserved. 21 Red Flag: Price-Fixing (cont’d) Agreement between competitors on pricing is almost always illegal Price-fixing is prohibited in both horizontal and vertical relationships Agreement between competitors to set minimum prices is blatant price-fixing Indirect agreements may also be illegal, e.g. to – Compare price lists before publication Exchange detailed information on each other’s production costs Agree on any other term of sale

22. Copyright© 2010 WeComply, Inc. All rights reserved. 22 Pop Quiz! Three companies dealing in lawn-mowers, a Belgian, Dutch and German company, agree that their customers will only be offered 15 days of credit instead of the normal 90 days of credit. Are these companies infringing on Article 101? A.Yes. B.No.

23. Copyright© 2010 WeComply, Inc. All rights reserved. 23 Red Flag: Market-Sharing Market-sharing: Agreement between competitors to divide up customers or geographical areas where they will not compete against each other Agreement to limit one competitor’s attempts to make sales is almost certain to be illegal Market-sharing in EU is particularly serious because it isolates geographical markets and hinders integration of EU countries into a single market

24. Copyright© 2010 WeComply, Inc. All rights reserved. 24 Red Flag: Limiting Output Cartel may enable price increases (or prevent reductions) by restricting production Agreements typically involve quota system of output allocations One company may agree to stop producing one product in exchange for other company stopping production of another product These agreements are serious violations and not likely to obtain exemption

25. Copyright© 2010 WeComply, Inc. All rights reserved. 25 Pop Quiz! The most important worldwide producers of chips for mobile phones are worried about serious over-capacity in the industry, which is reducing their profit margins. In fact, most producers are selling chips at a loss. The CEOs of these companies meet at a luxury spa resort just outside Bangkok in order to find a solution to their mutual problem. Instead of agreeing on specific quotas, which they believe will be very hard to monitor and enforce, they orally agree to shut down a number of production plants across Europe over a period of two years. They also agree to immediately reduce their production time by three hours a day and to refrain from investing in additional production capacity. Are the chip producers infringing Article 101? A.Yes. B.No.

26. Copyright© 2010 WeComply, Inc. All rights reserved. 26 Red Flag: Bid-Rigging Bid-rigging: Agreement amongst competitors to collaborate over their response to invitations to tender Typically, colluding companies agree which company will win current tender Next time there is a tender, another company will win, etc. Bid-rigging is a very serious cartel offense

27. Copyright© 2010 WeComply, Inc. All rights reserved. 27 Red Flag: Information-Sharing Competitors sometimes agree to exchange or share information Some information-sharing is legal and enhances competition Sharing confidential business information is serious violation, e.g. – Information on prices, rebates and other price-related information Production or distribution costs Forecast capacity Investment plans Content of information is decisive factor – not medium of exchange

28. Copyright© 2010 WeComply, Inc. All rights reserved. 28 Pop Quiz! The four members of the German trade organization for manufacturers of trucks agree to set up an information-exchange system to monitor sales of trucks in Germany and Austria. The trade organization designs a specific form to be filled out by manufacturers’ dealers every time the sale of a truck is registered. The dealer form contains information on the brand, the location of the dealer and the value of the sale. The trade organization compiles the information and provides it in a monthly report to the members. The information made available to the members identifies each individual member’s sales in different regions of Germany and Austria and provides a calculation of each member’s market share. Is the behaviour of the truck manufacturers or trade association infringing Article 101? A.Only the truck manufacturers. B.Only the trade association. C.Yes, both. D.No, neither.

29. Copyright© 2010 WeComply, Inc. All rights reserved. 29 Other Agreements with Competitors Consider competition rules before making any agreement with a competitor Some agreements between competitors are good for or neutral to competition, e.g. – To cooperate on R&D projects To pool resources for production and/or purchasing advantages To cooperate in commercialization of products To set industry standards Full analysis of economic/legal context is needed to determine legality

30. Copyright© 2010 WeComply, Inc. All rights reserved. 30 Vertical Agreements (cont’d) Vertical agreements: Agreements between companies of differing trade levels We may choose our own customers or suppliers, so long as we do so independently Only vertical agreements that include hardcore restrictions (e.g., price-fixing or market-sharing) are prohibited Block Exemption Regulation on Vertical Agreements (Verticals BER) is a guide Always have the Legal Department review business arrangements that raise any red flags

31. Copyright© 2010 WeComply, Inc. All rights reserved. 31 Verticals Block Exemption Regulation Set rules for vertical agreement exemptions If agreement falls within Verticals BER, parties can generally be sure that it is legal Some clauses are never exempt: Resale price maintenance Market-partitioning or absolute territorial restrictions on distributors Restrictions on a producer’s ability to sell spare parts Non-compete clauses lasting more than five years Post-termination clauses lasting more than one year Certain requirement contracts

32. Copyright© 2010 WeComply, Inc. All rights reserved. 32 Pop Quiz! Choco-ice has a market share of 25% of the ice cream market in the United Kingdom. It requires its retailers to buy 90% of their ice cream needs for eight years. It this clause exempted by the Verticals BER? A.Yes. B.No.

33. Copyright© 2010 WeComply, Inc. All rights reserved. 33 Red Flag: Resale Price Maintenance Resale price maintenance: Agreement between suppliers and distributors and/or retailers on how much they may charge their customers Commission has imposed substantial fines Setting recommended prices or maximum sales prices is generally not illegal if manufacturer allows distributor/retailer to determine price

34. Copyright© 2010 WeComply, Inc. All rights reserved. 34 Pop Quiz! A large publisher of children’s story books, Books R Us, has a range of distributors in each EU country. It informs its distributors of a recommended sales price for its books. When several distributors sell Books R Us’s books at discounted prices in Germany because it is national reading week, Books R Us does not react. Is Books R Us infringing Article 101? A.Yes. B.No.

35. Copyright© 2010 WeComply, Inc. All rights reserved. 35 Red Flag: Market-Partitioning Market-sharing agreements between competitors are illegal Market-sharing agreements may also be vertical – i.e., between suppliers and their distributors Producers may restrict distributors from selling outside an allocated territory Producers may not prevent distributors from responding to unsolicited orders from customers outside designated territory Commission has imposed large fines on distributors that took steps to prevent trade from one EU Member State to another

36. Copyright© 2010 WeComply, Inc. All rights reserved. 36 Red Flag: Market-Partitioning (cont’d) Market-sharing agreements between competitors are illegal Market-sharing agreements may also be vertical – i.e., between suppliers and their distributors Producers may restrict distributors from selling outside an allocated territory Producers may not prevent distributors from responding to unsolicited orders from customers outside designated territory Commission has imposed large fines on distributors that took steps to prevent trade from one EU Member State to another

37. Copyright© 2010 WeComply, Inc. All rights reserved. 37 Pop Quiz! Teleco manufactures televisions that it sells through its distributors. It has a market share of 25%. It enters into a series of contracts where it grants exclusive distribution agreements to distributors in each EU Member State. It prevents the distributors from selling actively into each other’s territories but allows passive sales. Is this exempted by the Verticals BER? A.Yes. B.No.

38. Copyright© 2010 WeComply, Inc. All rights reserved. 38 Relationships with Licensees Technology Transfer BER applies to transfers of intellectual property rights – e.g., patents, know-how and software copyright It creates safe harbor for certain licensing agreements: 1. Agreements between competitors where combined market share of parties does not exceed 20% 2.Agreements between non-competitors where market share of each party does not exceed 30% Agreements falling under Technology Transfer BER will be exempt from EU competition rules

39. Copyright© 2010 WeComply, Inc. All rights reserved. 39 Relationships with Licensees Technology Transfer BER will not apply if agreement contains - Price-fixing or resale price maintenance Most output limitations and customer allocations Restrictions on a licensee's ability to exploit its own technology or do R&D These clauses will be considered illegal: Requirement that improvements be licensed back to IPR holder Obligation not to challenge validity of IPR Agreement between non-competitors limiting licensee’s ability to exploit its own technology or do R&D

40. Copyright© 2010 WeComply, Inc. All rights reserved. 40 Pop Quiz! Compusoft has a computer technology for providing electronic maps in cars. It has a market share of 25%. It licenses its technology to Fastcar (a non-competitor) to put in their vehicles. Is this agreement exempt? A.Yes. B.No. C.It Depends.

41. Copyright© 2010 WeComply, Inc. All rights reserved. 41 Article 82 EC: Abuse of Market Dominance Article 102 is a companion of Article 101 Directed at unilateral conduct of companies dominant in their market Targets abuse of dominant position Abuse of a dominant position: Anti-competitive business practice undertaken to maintain or increase market position Includes unfair pricing, restriction of production output, and imposing discriminatory terms on trading partners Violations of Article 102 can result in serious fines and other penalties

42. Copyright© 2010 WeComply, Inc. All rights reserved. 42 Article 82 EC: Abuse of Market Dominance (cont’d) Article 102 is a companion of Article 101 Directed at unilateral conduct of companies dominant in their market Targets abuse of dominant position Abuse of a dominant position: Anti-competitive business practice undertaken to maintain or increase market position Includes unfair pricing, restriction of production output, and imposing discriminatory terms on trading partners Violations of Article 102 can result in serious fines and other penalties

43. Copyright© 2010 WeComply, Inc. All rights reserved. 43 What Is a Dominant Position? Dominant company has economic strength to behave independently of its competitors, customers and consumers Company with market share under 30% is not dominant Company market share of more than 40% is generally considered dominant Between 30% and 40%, question of dominance depends on other factors, e.g. – General competitive outlook of market structure Number of competitors in market Market share over 50% generally creates legal presumption of dominance

44. Copyright© 2010 WeComply, Inc. All rights reserved. 44 What Is a Dominant Position? (cont’d) Dominant company has economic strength to behave independently of its competitors, customers and consumers Company with market share under 30% is not dominant Company market share of more than 40% is generally considered dominant Between 30% and 40%, question of dominance depends on other factors, e.g. – General competitive outlook of market structure Number of competitors in market Market share over 50% generally creates legal presumption of dominance

45. Copyright© 2010 WeComply, Inc. All rights reserved. 45 In the news…

46. Copyright© 2010 WeComply, Inc. All rights reserved. 46 Market Dominance Red Flags Red Flag: Tying Dominant company may not make sale of one product conditional on purchase of another unless objectively justified Company may not use dominance in tying market on tied market Tying is prohibited even when apparently beneficial to consumers Red Flag: Loyalty Discounts Dominant company may not offer its customers special discounts to discourage alternatives Any discount arrangement must be based on fair grounds

47. Copyright© 2010 WeComply, Inc. All rights reserved. 47 Market Dominance Red Flags (cont’d) Red Flag: Tying Dominant company may not make sale of one product conditional on purchase of another unless objectively justified Company may not use dominance in tying market on tied market Tying is prohibited even when apparently beneficial to consumers Red Flag: Loyalty Discounts Dominant company may not offer its customers special discounts to discourage alternatives Any discount arrangement must be based on fair grounds

48. Copyright© 2010 WeComply, Inc. All rights reserved. 48 Market Dominance Red Flags (cont’d) Red Flag: Exclusivity Dominant company may not force customers to purchase all/most of their requirements from it Red Flag: Refusal To Supply Dominant company must supply everyone, absent non-discriminatory and objectively justified criteria for it not to do so Can apply to supplying a competitor Red Flag: Long-Term Agreements Dominant company’s entrance into long-term, no-termination contracts can be abuse of dominance

49. Copyright© 2010 WeComply, Inc. All rights reserved. 49 Market Dominance Red Flags (cont’d) Red Flag: Exclusivity Dominant company may not force customers to purchase all/most of their requirements from it Red Flag: Refusal To Supply Dominant company must supply everyone, absent non-discriminatory and objectively justified criteria for it not to do so Can apply to supplying a competitor Red Flag: Long-Term Agreements Dominant company’s entrance into long-term, no-termination contracts can be abuse of dominance

50. Copyright© 2010 WeComply, Inc. All rights reserved. 50 Market Dominance Red Flags (cont’d) Red Flag: Discriminatory Business Terms Dominant company may not discriminate amongst customers, absent fair and objectively justified grounds Red Flag: Predatory Pricing Dominant company may not sell products at prices below cost to drive competitors out of business Red Flag: "English Clauses" English Clause: Agreement between dominant company and customer that customer will not accept offer from another supplier until dominant company has declined to match it

51. Copyright© 2010 WeComply, Inc. All rights reserved. 51 Market Dominance Red Flags (cont’d) Red Flag: Discriminatory Business Terms Dominant company may not discriminate amongst customers, absent fair and objectively justified grounds Red Flag: Predatory Pricing Dominant company may not sell products at prices below cost to drive competitors out of business Red Flag: "English Clauses" English Clause: Agreement between dominant company and customer that customer will not accept offer from another supplier until dominant company has declined to match it

52. Copyright© 2010 WeComply, Inc. All rights reserved. 52 Pop Quiz! SuperClean lowers the price of its household bleach product to a level where it is producing a loss. At the same time, it raises the price of its window-cleaning product, a market on which it is dominant. Two of SuperClean’s competitors on the household bleach market are forced out of that market. SuperClean subsequently raises the price of bleach to 10% above what it was originally charging. Which of the following red flags does SuperClean’s conduct signal? A.Tying. B.English Clause. C.Predatory pricing. D.Exclusivity arrangement. E.Refusal to supply.

53. Copyright© 2010 WeComply, Inc. All rights reserved. 53 Investigation and Enforcement Under Regulation 1/2003, Commission can - Enter and seal premises inside the EU Examine private homes and cars of personnel inside the EU Examine and copy companies' business documents Download from computers and copy email files Question individuals on site Impose fines for failure to cooperate with investigation

54. Copyright© 2010 WeComply, Inc. All rights reserved. 54 Investigation and Enforcement (cont’d) Under Regulation 1/2003, Commission can - Enter and seal premises inside the EU Examine private homes and cars of personnel inside the EU Examine and copy companies' business documents Download from computers and copy email files Question individuals on site Impose fines for failure to cooperate with investigation

55. Copyright© 2010 WeComply, Inc. All rights reserved. 55 Investigation and Enforcement (cont’d) Companies must comply with Commission inspection decisions and cooperate with inspectors Non-cooperation may lead to procedural fine or increase in amount of overall fine On an individual level – Cooperate with Commission officials Don’t attempt to co0nceal or destroy documents Both company and personal liability are at stake

56. Copyright© 2010 WeComply, Inc. All rights reserved. 56 In the news…

57. Copyright© 2010 WeComply, Inc. All rights reserved. 57 "Dawn Raids" Commission officials have power to conduct inspection visits Inspections can occur without any warning at any time Survival tips: Cooperate, be friendly and stay alert Inform management, Legal Department and external counsel Ensure that search stays within its scope Don’t destroy documents while investigation is going on Keep accurate minutes

58. Copyright© 2010 WeComply, Inc. All rights reserved. 58 "Dawn Raids" – Documents (cont’d) We may not be legally required to hand over all requested documents Communications with external counsel are protected by legal professional privilege If Commission officials request privileged documents from you – Refuse to provide documents based on attorney-client privilege If officials insist, request that documents be placed in sealed envelope until legal status can be ascertained

59. Copyright© 2010 WeComply, Inc. All rights reserved. 59 "Dawn Raids" – Documents (cont’d) We may not be legally required to hand over all requested documents Communications with external counsel are protected by legal professional privilege If Commission officials request privileged documents from you – Refuse to provide documents based on attorney-client privilege If officials insist, request that documents be placed in sealed envelope until legal status can be ascertained

60. Copyright© 2010 WeComply, Inc. All rights reserved. 60 Enforcement - Leniency Programme Companies can apply for more lenient treatment by “confessing” to Commission This encourages cartel parties to “blow whistle” on cartel activities/members First party to confess may receive 100% reduction from any fine Other parties who confess may receive significant reductions, but much less than first whistleblower

61. Copyright© 2010 WeComply, Inc. All rights reserved. 61 Enforcement - Leniency Programme (cont’d) If you participate in or learn of anticompetitive discussions – Competitor may disclose all your discussions, writings, etc., to competition authorities in exchange for leniency o Do not trust any of your competitors! Report incident as soon as possible to management and/or Legal Department to give our company a chance to be first to apply for leniency o Report it orally to avoid creating documents that could be seized by competition authorities

62. Copyright© 2010 WeComply, Inc. All rights reserved. 62 Pop Quiz! You are new to your job and realize that your predecessor was regularly exchanging prices with the company’s competitors. Which of the following presents your best course of action? A.Continue your predecessor’s activities if it would be helpful for the company. B.Stop exchanging prices with competitors and inform your Legal Department as quickly as possible. C.Phone the authorities directly to report the conduct.

63. Copyright© 2010 WeComply, Inc. All rights reserved. 63 Careful Communication Consider carefully your language in both internal and external communications Ill-considered language can be very damaging It can make legal activity appear illegal It can colour authorities’ or complaining parties’ views as to intent Be careful with both written and oral communications Competition law authorities are looking to careless statements in email as proof of anti-competitive conduct or intent

64. Copyright© 2010 WeComply, Inc. All rights reserved. 64 Careful Communication (cont’d) Consider carefully your language in both internal and external communications Ill-considered language can be very damaging It can make legal activity appear illegal It can colour authorities’ or complaining parties’ views as to intent Be careful with both written and oral communications Competition law authorities are looking to careless statements in email as proof of anti-competitive conduct or intent

65. Copyright© 2010 WeComply, Inc. All rights reserved. 65 Rules for Written Communication Speak to in-house counsel before recording matters in sensitive areas Consider that what you record could be viewed by a third party – e.g., judge or regulator – in due course Don’t use “guilty” vocabulary Avoid speculation about legality/illegality of your conduct Don’t express your doubts in written communications

66. Copyright© 2010 WeComply, Inc. All rights reserved. 66 Pop Quiz! Which of the following phrases would be appropriate in either internal or external communications? A.To be destroyed after reading. B.It has been agreed not to make any notes. C.During the negotiations, the customer told me that our competitor’s price for this quarter is 200. D.My source told me that our competitor’s price for this quarter is 200.

67. Copyright© 2010 WeComply, Inc. All rights reserved. 67 Rules for Multi-Party Agreements Avoid any suggestion that a collection of competitors has reached a view on a particular issue Do not record anything implying that prices are based on something other than the company's independent business judgment State clearly the source of any pricing information Ensure that you keep accurate records of all competitor contacts and review notes with Legal Department

68. Copyright© 2010 WeComply, Inc. All rights reserved. 68 Rules for Dominant Companies Avoid giving any customer the impression that it is getting special treatment Avoid – o "This will enable us to dominate the market" o "We have virtually eliminated the competition" Avoid suggesting that company has a strategy to drive out competitors

69. Copyright© 2010 WeComply, Inc. All rights reserved. 8/23/2015 Final Quiz

70. Copyright© 2010 WeComply, Inc. All rights reserved. 8/23/2015 Questions?

71. Copyright© 2010 WeComply, Inc. All rights reserved. 8/23/2015 Thank you for participating! This course and the related materials were developed by WeComply, Inc. and the Association of Corporate Counsel.