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    Competition Law Surprise Inspections Do's and Don'Ts - Incl Contact Info

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    lngcivil
    The document provides guidance on what to do in the event of an unannounced inspection (dawn raid) by competition authorities at an AkzoNobel premises. It lists both "DOs" and "DON'Ts" for employees. The "DOs" include immediately calling the response team and legal counsel, remaining calm and cooperative, and making copies of all documents reviewed by inspectors. The "DON'Ts" include destroying documents, denying access, speculating about the purpose of the inspection, and refusing to answer questions. Contact information is provided for AkzoNobel's legal group and outside counsel.

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    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd

    Competition Law Surprise Inspections Do's and Don'Ts - Incl Contact Info

    Uploaded by

    lngcivil
    44 views1 page
    The document provides guidance on what to do in the event of an unannounced inspection (dawn raid) by competition authorities at an AkzoNobel premises. It lists both "DOs" and "DON'Ts" for employees. The "DOs" include immediately calling the response team and legal counsel, remaining calm and cooperative, and making copies of all documents reviewed by inspectors. The "DON'Ts" include destroying documents, denying access, speculating about the purpose of the inspection, and refusing to answer questions. Contact information is provided for AkzoNobel's legal group and outside counsel.

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    Competition Law Surprise Inspections Do's and Don'Ts_Incl Contact Info

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    The document provides guidance on what to do in the event of an unannounced inspection (dawn raid) by competition authorities at an AkzoNobel premises. It lists both "DOs" and "DON'Ts" for employees. The "DOs" include immediately calling the response team and legal counsel, remaining calm and cooperative, and making copies of all documents reviewed by inspectors. The "DON'Ts" include destroying documents, denying access, speculating about the purpose of the inspection, and refusing to answer questions. Contact information is provided for AkzoNobel's legal group and outside counsel.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    44 views1 page

    Competition Law Surprise Inspections Do's and Don'Ts - Incl Contact Info

    Uploaded by

    lngcivil
    The document provides guidance on what to do in the event of an unannounced inspection (dawn raid) by competition authorities at an AkzoNobel premises. It lists both "DOs" and "DON'Ts" for employees. The "DOs" include immediately calling the response team and legal counsel, remaining calm and cooperative, and making copies of all documents reviewed by inspectors. The "DON'Ts" include destroying documents, denying access, speculating about the purpose of the inspection, and refusing to answer questions. Contact information is provided for AkzoNobel's legal group and outside counsel.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 1

    Competition Law Surprise

    Inspections at company
    premises (Dawn Raids) July 2019

    Principle Save these do’s and don’ts on


    Competition authorities can conduct unannounced inspections (also known as dawn raids) at your devices for easy access:
    one of AkzoNobel’s premises if they suspect a competition law violation. The inspectors have For business smartphone click here
    extensive powers: they can take away physical or electronic records (for instance including For personal smartphone
    private smartphones) and ask questions to individuals. AkzoNobel is legally obliged to submit to http://akzo.no/surpriseinspections
    or ask us for a PDF if you also want
    the inspection and, while we should not volunteer any information, we must cooperate with the
    the contact details
    inspectors and avoid any obstruction to their work.
    Tap the “share” button on your
    browser’s toolbar (the rectangle with
    What to do: an arrow pointing upwards), then
    tap the “add to home screen” icon
    Immediately call the response team and follow the DOs and DON’Ts below

    DOs DON’Ts

    IMMEDIATELY CALL OUR RESPONSE TEAM: A


     part from our response team (see box on the left), do
    1. Your site and BU managers not inform anyone else within or outside of AkzoNobel
    2. Your Productivity Support Officer for IT-related questions
    Do not destroy, delete, hide or take away any documents
    (contacts here)
    or e-mails, not even personal or embarrassing ones
    3. AkzoNobel Legal Group (contacts below),
    who in turn will call our outside legal counsel Do not be impolite or defensive

    Remain calm and professional Do not deny the inspectors access or refuse to cooperate
    – But do not show them anything on your own initiative
    Know who the inspectors are and what they want
    – Ask for name, title, and which authority they represent Do not refuse to answer the questions from the
    – Ask for decision/warrant and make a copy inspectors
    – But do not tell the inspectors anything on your own initiative
    A
     sk the inspectors to wait briefly for the response team and do not give opinions or voice concerns (for instance do
    and legal counsel to arrive not speculate about the purpose of a meeting, limit yourself
    – Be polite and hospitable (offer coffee) to a factual response for instance about who attended
    – Bring them to an empty conference room the meeting)
    (with no business documents or computers)
    – If they refuse to wait (and they can after approx 20 minutes), Do not show the inspectors anything (not even a glimpse)
    
    always accompany them that is marked LEGALLY PRIVILEGED or something
    similar. Suggest to them that the document should be put
    A
     lways escort inspectors in a sealed envelope and wait for legal counsel
    – Record everything: what items, files and places they look at,
    used search/keywords, what they ask, and what answers Never break any seals affixed by the inspectors
    are given
    – Copy everything for them and for us (twice) Never sign anything without legal counsel’s consent
    – If possible, stamp/label everything as CONFIDENTIAL
    – Keep your answers polite but short and factual

    AkzoNobel Legal Group contacts*

    Director Regional Focal Points SOUTH AMERICA NORTH ASIA EUROPE UNITED KINGDOM
    Competition Law Marcia Romano Santo Le Cheng Charlotte van Meer Marni Lancaster
    NORTH AMERICA T +55-1121091122 T +86-2122205828 T +31889697935 T +44-2079329909
    Gianni De Stefano & Peter Drucker M +55-11991691288 M +86-13661588070 M +31615439510 M +44-7711128966
    T +31-889691661 T +31889697392
    M +31-650059925 M +31629259913 SOUTH ASIA Michael Liang MIDDLE EAST AND
    Surabhi Agarwal T +86-2122205826 AFRICA
    T +65-84283640 M +86-13512158030 Sari Kanaan
    * Contact both the Director M +91-9818466451 T +971-43762410
    Competition Law and M +971-552421227
    your Regional Focal Point

    AkzoNobel Legal Group in turn will call our outside legal counsel – list here

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