CASE COMMENTS: REGULATORY - BROCHURE ON COMPLIANCE - MITIGATING/AGGRAVATING CIRCUMSTANCES
Compliance Program: The Commission publishes a brochure on compliance but sticks to its guns: no pay for the implementation of a compliance program and no mitigating circumstances or aggravating circumstances
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On 23 November 2011, the Commission published online a brochure Compliance matters - What companies can do better to respect EU competition rules", designed to encourage and support companies in the implementation of a compliance program.
However, there's nothing to get excited about... True to its traditional approach, the Commission stands firm on its positions regarding the consequences it intends to attach to the existence or implementation of a compliance program. As reaffirmed from the outset on the DG Competition website page
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