INTERVIEW: COMPLIANCE PROGRAMMES - REPORT FRENCH NCA - EUROPE ECONOMICS - NORTON ROSE - BEST FEATURES - EFFICIENCY - EFFECTIVENESS - BEST PRACTICES

Carol XUEREF, Essilor & François GARNIER, Pfizer: Compliance policies - The counsels’ points of view

In order to examine whether it would be appropriate to develop or encourage the adoption of compliance programmes in France, the French Competition Council commissioned Europe Economics, in conjunction with Norton Rose, to conduct a study of compliance programmes. The conclusions of this study have been made public early November 2008. Amongst other key questions the study attempts to answer are what are the best features, the efficiency and effectiveness of a compliance programme and what policies and practices have been adopted by other competition authorities. The interview of Mme Carol Xueref, Director for Legal Affairs and Group Development, and Member of the French Competition Council, directly involved in the Competition Council working group on compliance, provides detail on the conclusions of this study and on the expected actions to be taken by the Council. The interview of M. François Garnier, Director for Legal Affairs and President of the Cercle Montesquieu, gives details on the point of view on an in-house lawyer on compliance policies.

- The French Competition Council has released a report on compliance policies in Europe in October 2008. Could you summarize the best policies guidelines proposed by this report?

- How will the Competition Council follow up with this report?

- What are the main differences - if any - between antitrust compliance programs and others compliance programs in fields such as finance, accounting, environment etc.?

- What are the goals of an antitrust compliance policy for a company?

- Which roles employees and their committees can play in compliance?

- Does the implementation of an antitrust compliance program help people within the firm to think more about legal constraints?

- You mentioned that it would be difficult for a competition authority to establish a general method to assess compliance programs. Could you suggest a set of criteria?

- What are the outside obstacles to implementation of a compliance program (privacy and employment regulations etc.)?

- As head of Pfizer legal department, you mentioned that Pfizer is “at the same time the best and the worst“ in terms of compliance program. Could you elaborate on this?

The French Competition Council has released a report on compliance policies in Europe in November 2008. Could you summarize the best policies guidelines proposed by this report? Carol Xueref: In order to examine whether it would be appropriate to develop or encourage the adoption of compliance programmes in France, the French Competition Council commissioned Europe Economics, in conjunction with Norton Rose, to conduct a study of compliance programmes. Amongst other key questions the study attempts to answer are what are the best features, the efficiency and effectiveness of a compliance programme and what policies and practices have been adopted by other competition authorities. With regard to best policies guidelines for the programmes themselves, Europe Economics formulated

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François Garnier, Carol Xueref, Carol XUEREF, Essilor & François GARNIER, Pfizer: Compliance policies - The counsels’ points of view, December 2008, Concurrences Review N° 4-2008, Art. N° 22378, www.concurrences.com

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