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Cartel investigations and dawn raids

We have acted in many high profile cartel investigations undertaken by the European Commission and by national competition authorities in the UK and Germany. Additionally, we have experience in defending individuals in respect of criminal cartel investigations in the UK.

Clients who are the subject of a cartel investigation by the European Commission or national competition authorities in the UK and Germany can benefit from our experience in handling leniency applications, developing a defence strategy, responding to information requests, preparing defences, negotiating settlements where necessary and advising on likely penalties. As an integral part of any defence strategy, we would seek to minimise our clients' exposure to the risk of subsequent competition damages actions.

Dawn raids are one of the ways cartel investigations are launched by competition authorities, both on a national and European level.  We have extensive experience in the containment and on-the-ground management of dawn raids conducted throughout the UK and are able to offer clients a wide variety of resources from a 24 hours dawn raid hotline, dawn raid manuals for staff, to employee training. We have designed and provided bespoke dawn raid manuals and training for many industries including energy, manufacturing, engineering, pharmaceutical, aerospace, construction products, construction, door hardware, life sciences and distribution.

Recent experience includes:

  • acting for a client in relation to the European Commission's investigation into the Yen LIBOR cartel including its successful leniency application and settlement submission;
  • acting for more than six construction companies in relation to the investigation into cover pricing arrangements in the UK construction industry, including successfully obtaining 100% immunity from fines for one of the companies;
  • acting for a client in relation to the European Commission's investigation of ship classification societies, in both the dawn raid and the subsequent processes including successful negotiating of commitments to avoid a fine; and
  • acting for a UK manufacturer in relation to the European Commission's investigation into cement and related sectors; and
  • acting in relation to two ongoing criminal cartel investigations in the UK.