Hong Kong Competition Ordinance: First Conduct Rule* In this article we explore the First Conduct Rule in Hong Kong’s Competition Ordinance, focusing on its significance for companies preparing for implementation of the Ordinance. Overview of the First Conduct Rule The First Conduct Rule targets anti-competitive agreements, including serious or ‘hardcore’ coordination between competitors such as price-fixing, market allocation, output restriction or bid-rigging. Hong Kong’s Competition Commission has indicated that it will be particularly focused on this type of conduct. The Chairperson of the Commission, Ms Anna Wu, has singled out price-fixing cartels as initial targets, stating that she is determined to tackle the “Big Tigers” of Hong Kong. Compliance Drive Both Ms Wu and Senior
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The Hong Kong’s Competition Commission gives some advice to companies preparing for implementation of the Competition Ordinance
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