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12 - Hong Kong’s Revised Leniency Policy and Its Potential to Deter Cartels

from Part III - Leniency Programmes in Selected Asian Jurisdictions

Published online by Cambridge University Press:  15 September 2022

Steven Van Uytsel
Affiliation:
Kyushu University, Japan
Mark Fenwick
Affiliation:
Kyushu University, Japan
Yoshiteru Uemura
Affiliation:
Hannan University, Japan
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Summary

The chapter reports that the leniency programme in Hong Kong was promulgated at the same time that the Hong Kong Competition Ordinance went into full effect in 2015. This leniency programme has been successfully used once. The Hong Kong Competition Commission (HKCC) reached a leniency agreement in 2020, despite the strong focus of the HKCC on tackling cartels. Six out of the seven cases the HKCC has brought to the Hong Kong Competition Tribunal are cartel related. These enforcement successes are attributable to market studies of the HKCC itself. However, this situation should not be misinterpreted. With the arrival of Brent Snyder as the Chief Executive Officer of the HKCC, the leniency programme was revised. Lenient treatment remained limited to immunity, but also became available once an investigation has started. Two new schemes were introduced: leniency for individuals and leniency plus. A leniency applicant has also been given immunity from damages claims. Further, reduction was made possible through the introduction of a cooperation policy. These recent changes should contribute to enforcement and supplement the successfully concluded ex officio investigations.

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Publisher: Cambridge University Press
Print publication year: 2022

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