Andrey Tenishev outlined the criteria for evaluating efficiency of compliance systems
Head of FAS Anti-Cartel Department discussed specifics of adopting antimonopoly compliance by companies.
“First, a compliance document should be drawn up; second, all company staff should become aware of it. A compliance programme should be renewed in line with the changes in the antimonopoly law and relevant trainings should be organized for the personnel”, pointed out Andrey Tenishev at a workshop on “Antimonopoly Compliance: Theory and Practice” on 14 March 2017.
He described FAS initiative on stimulating development of compliance systems at the legislative level. The draft law prepared by the Antimonopoly Service specifies positive legal consequences for the companies that use this institution in their operations.
“Advantages of adopting antimonopoly compliance include preventing reputational damage, preventing violations and possible administrative leniency. Adopting this institution within a company is one of the elements enabling to make the business community aware that there is prohibition of anticompetitive agreements”, stated Andrey Tenishev.
He said that just adopting a compliance document by an economic entity is not a “forgive” from a committed violation. Only a correctly built up and working compliance system will be considered a mitigating circumstance against a committed violation when FAS investigates cases on administrative violations.