in the organisation. The compliance programme should be
aligned with the business strategy and other policies, such as
the code of conduct and disciplinary code.
development of the competition law compliance programme.
It is important that all management and staff know who the
compliance officer is in case they have any questions about
competition law or the compliance programme, or if they have
any information about improper conduct.
commitment to comply fully with competition law.
in the business why compliance is important. The programme
should include an overview of potential infringements of
competition law, setting out the powers of the Competition
Authority when investigating possible infringements and
explaining what the consequences are for individuals and com-
panies.
be supported in all of the business' codes of practice, policies
and procedures. The programme should make it clear that
management and employees all have a duty to comply with
the law. The compliance officer should deal with questions and
concerns about compliance and should be in a position to get
advice on whether practices comply with competition law.
non-compliance, through the compliance officer, to senior
management. Ideally the person reporting the problem should
be dealt with in confidence, if possible.
programme should also clearly state the disciplinary action that
the company will take against staff who do not comply.
Management and staff should all be clear about all of the
consequences of not complying with the programme.
compliance
your business
competition law
of compliance procedures for non-compliance and
disciplinary action for non compliance