On 16 April 2020, the Hong Kong Competition Commission (HKCC) introduced significant reforms to its leniency policies.
Businesses engaged in cartels that may impact Hong Kong will need to carefully assess, with their advisors, the pros and cons of making a leniency application.
The revised leniency policies increase the benefits for leniency applicants. They are not required to submit to Tribunal proceedings and, in the case of leniency applicants who come forward before the Commission becomes aware of an infringement, will not be required to submit to a declaration of breach (and as a result, they will receive de facto immunity from follow on damages actions in Hong Kong).
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