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Cooperation under the Leniency Program and the Settlement
Procedure.
The detection mechanisms provided by an effective com-
pliance strategy can also help to get the best out of the Commission’s
leniency program. Aimed at enabling the detection of secret agree-
ments between competitors, it offers a unique opportunity for under-
takings willing to cooperate with the Commission, to receive immuni-
ty from fines or to get a fine reduced.
Finally, if undertakings are prepared to acknowledge their partic-
ipation in a cartel, the Commission may invite them to participate in a
swifter conclusion of the procedure. The undertakings’ cooperation in
this “settlement” procedure is rewarded with a 10% reduction of the
fine in addition to any reduction for leniency.
Conclusion
The publication of such a Brochure is extremely helpful for under-
takings. Indeed, this Brochure will ensure that undertakings are aware,
on the one hand, of the risks of non-compliance with EU competition
rules and on the other hand, of the steps that they can take in order to
ensure compliance.
The preparation of such a Brochure would also be appropriate in
Turkey. As a matter of fact, a lot of undertakings are still not aware of
the competition rules considering that competition law is a new field
which is applied for only 15 years.
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