国际商会国际仲裁院-ICC反垄断合规工具包（英）

Antitrust Compliance ToolkitSecond editionICC (2024) Antitrust Compliance Toolkit | Second editionCopyright © 2024 International Chamber of Commerce© 2024, International Chamber of Commerce (ICC)The text below is a collective work, initiated and drafted under the authority and control of ICC, and to which ICC holds all rights.Participation in the development of this text will not give rise to any rights for contributors in this collective work, of which ICC is sole copyright holder.This shall not affect pre-existing rights in extracts from third party texts included in this Toolkit which shall remain vested in the copyright holder of those texts.Express written permission must be obtained for any modification, adaptation or translation, for any commercial use, and for use in any manner that implies that another organisation or person is the source of, or is associated with, the work.The work may not be reproduced or made available on websites except through a link to the relevant ICC web page (not to the document itself).Permission can be requested from ICC through ipmanagement@iccwbo.orgICC Publication No. 450/1081-12E ISBN: 978-92-842-0698-82go.iccwbo.orgICC (2024), Antitrust Compliance Toolkit | 2In memoriamThe International Chamber of Commerce (ICC) dedicates the second edition of its Antitrust Compliance Toolkit (Toolkit) to Anne Riley in tribute to her exceptional leadership in the field of antitrust compliance and advocacy. A trusted colleague and friend to many of the contributors to this publication, Anne played a pivotal role in the elaboration of the first edition of the Toolkit in 2013 and its SME version in 2015. Her insights and deep expertise are reflected throughout this updated Toolkit—reflecting the unique vision and passion she brought to this field. She was so passionate that she did not hesitate to challenge herself the approach taken in the 2013 version of the Toolkit, with a view to adapt the new edition to the evolution of antitrust compliance in the last decade.Anne will be deeply missed throughout the antitrust community, but her legacy as a thought leader and innovator will most certainly endure.ICC (2024), Antitrust Compliance Toolkit | 3Foreword by Olivier Guersent, Director General for Competition of the European CommissionIn today’s world, businesses operate in a complex and rapidly changing landscape where there is an increased need to be aware of the dividing line between legitimate commercial behaviour and illegal anti-competitive practices. With authorities around the world engaging in strong enforcement against such illegal practices, compliance with competition law is now of paramount importance. But compliance is not simply a legal requirement, rather it is a business necessity, which brings many benefits to companies. It serves to avoid the imposition of potentially large fines from public authorities and damages actions from private victims. It allows businesses to uncover illegal cartel behaviour that