UK: EC Competition Law

Last Updated: 28 January 2003
Article by Rob Sully

Commission Notice on Immunity from Fines: the "whistle blowers charter"

19/02/02 OJ C45/9

In 1996 the Commission adopted a Notice providing for the non-imposition or reduction of fines for participants in cartels who decided to blow the whistle or otherwise co-operate with the Commission in providing evidence leading to a prohibition decision.

This new 2002 Notice, which replaces the 1996 version, is more specific as to the circumstances under which immunity from fine will be granted and the "tariffs" for fine reduction where a cartel member has co-operated in a Commission investigation.

The Commission will grant an undertaking immunity from fine if it is the first to submit evidence triggering the Commission’s investigation or to enable the Commission to find that there has been an infringement of Article 81. Immunity will not be available if the Commission already has sufficient evidence either to carry out the investigation or to find an infringement. In such circumstances, however, a reduction in fine may be available.

Any such immunity is conditional upon the undertaking concerned co-operating fully "on a continuous basis and expeditiously" with the investigation. The undertaking must end its involvement in the cartel and must not have been involved in any attempt to coerce other undertakings to participate in the infringement.

Fine reductions will be available where an undertaking provides evidence of the suspected infringement "which represents significant added value with respect to the evidence already in the Commission’s possession".

The first undertaking which supplies such evidence would benefit from a reduction of fine of 30-50%, the second undertaking a reduction of 20-30% and any subsequent undertakings would obtain a reduction of up to 20%.

"The Fight against Cartels"

Speech of Competition Commissioner Mario Monti, Brussels

11th September 2002

At a talk given to EMAC in Brussels on the 11th September 2002, Mario Monti, the European Commissioner in charge of Competition Policy, explained that 2001 had been a record year for the discovery of cartels, with ten cartels involving 61 firms being investigated by the Commission. In total these companies had fines imposed on them amounting to € 1.8 billion.

Mr Monti said that the fight against cartels was given increased priority around 1998, when the Commission increased the resources devoted to the work. During this period the number of officials engaged on the investigation of cartels doubled. A further increase in resources to fight cartels was planned for this year.

Mr Monti added that the Leniency Rules had been successful in encouraging companies to disclose participation in cartels in return for immunity from fine and expected that the recent changes in the Rules should further boost the discovery and elimination of cartel behaviour.

Motor vehicle Distribution publication

Press Release: IP/02/1392

On the 30th September 2002, the Commission published an explanatory brochure on the new group exemption for motor car distribution and servicing which entered into force on 1 October 2002.

The brochure provides a user-friendly guide to the consumer of their rights and obligations under the new regulations. Using a ‘question and answer’ format it also explains the philosophy underpinning the regulations and competition laws within Europe, in order that the new rules are implemented efficiently.

The purpose of the new group exemption (EC Regulation 1400/2002) is to promote competition, quality and choice in the maintenance sector and enhance dealers’ commercial independence. Distributors are now able to operate with greater freedom and to open multi-brand dealerships. Independent repairers are now granted access to technical information.

The brochure is available on the Competition DG’s website:

- Http://

Fines imposed on Industrial Gases cartel

for price fixing


NV Hoek Loos – AGA AB – Air Liquide BV – Air Products Nederland BV – BOC Group Plc – Messer Nederland BV – Westfalen Gassen Nederland BV

On 24 July 2002 the Commission fined seven producers of industrial and medical gases a total of € 25.72m. This was for participating in a cartel in the Netherlands between 1993 and 1997.

The Commission identified that the companies had regular meetings to discuss price increases and other unfavourable trading conditions offered to customers, including:

• minimum prices when offering bulk sales to new clients

• introduction of delivery and transportation charges for supplies of bulk sales

• environmental and safety charges on supplies of gas cylinders

• charging rent for gas cylinders

• arranging not to deal with each other’s customers for a period in the year, usually between 2–5 months, in order to increase prices and retain their customers.

The Commission found that this was a clear breach of competition law and accordingly fined the seven companies between € 0.43m and € 12.6m each. The Commission calculated the individual fines according to the level of participation in the cartel and their co-operation with the investigation.

Fines imposed on Citric Acid producers cartel for restricting competition

06/09/02 OJ L239/18

Archer Daniels Midlands Company Inc – Cerestar Bioproducts BV – F.Hoffmann-La Roche AG – Haarmann & Reimer Corporation – Jungbunzlauer AG

The Commission has fined five companies a total of € 135.22m for their participation in a cartel in the citric acid industry. The Commission identified that the infringement began in 1991 when the companies, headed by Hoffmann-La Roche, arranged meetings to consider how to improve the sales of citric acid after the decline in sales in the late 1980’s. The cartel pursued four main objectives:

• sales quotas were established for each company, which were based on a market share figure

• ‘floor’ and ‘target’ pricing, to ensure minimum price levels were maintained

• price discounts to customers were stopped, except to the five largest consumers

• detailed customer information was exchanged

The Commission also uncovered evidence that a monitoring system was established to make sure the objectives were maintained. The companies achieved this by regular meetings and the exchange of monthly sales figures. The companies also established a compensation scheme that penalised companies that went over their sales quotas and compensated those who did not reach it.

The cartel continued to operate until May 1995 when the cartel came to an end due to growing imports from China and cheating on the part of cartel participants.

Fines imposed on Mercedes Benz for the imposition of export bans and other territorial restrictions on distributors

25/09/02 OJ L257/1

Following receipt of a number of consumer complaints concerning restrictions on the export of new motorvehicles by Mercedes Benz, the Commission carried out an investigation into the Mercedes Benz European dealership network from which the following anti-competitive practices were identified:

• export restrictions in Germany, where Mercedes Benz had instructed its agents on several occasions not to sell vehicles outside their contract territory and had tried to make it more difficult for them to engaged in parallel exporting

• a prohibition in Germany and Spain of supplying outside leasing companies where there was no specific lessee. The Commission found that this made it impossible for leasing companies to purchase large volumes of cars and sell from stock, thereby obtaining the same price advantages as fleet operators, both in terms of prices and delivery conditions

• the setting of sales prices in Belgium through an agreement between Mercedes Benz and the dealers association to limit discounts to 3% and having a test buyer check the level of discounts on certain vehicles

The Commission took the view that the infringements identified above were particularly serious, although of medium duration. The Commission rejected Mercedes Benz’s argument that the fact that the infringements were perpetrated by junior staff and not by members of the managing board was a mitigating factor. The Commission indicated that if staff send circulars or letters in the course of their duties to agents or dealers, then the manufacturer must take responsibility. A fine of EUR 71,825 million was imposed.

Of interest in relation to market definition in the motor vehicle sector is that the decision divides the domestic car market into a number of segments based on factors such as purchase price and vehicle length, taking the view that other factors such as engine capacity, quality and brand image play a smaller role in determining the segment to which a vehicle belongs. The Commission identified the following segments:

• very small cars;

• small cars;

• medium cars;

• upper medium cars;

• executive cars;

• luxury cars;

• multi purpose vehicles and sports cars.

Fine imposed on Sotheby’s for price fixing, but Christie’s escapes fines under the "whistle blowers" immunity scheme


In a decision adopted on 30 October 2002, the Commission found that the world’s two leading auction houses, Sotheby’s and Christie’s, had breached EU Competition rules.

Between 1993 and early 2000 it was established that both parties had entered into an anti- competitive cartel agreement that fixed commission fees and other trading terms, with the aim of reducing the fierce competition which had previously existed between the two companies.

The Commissions investigation began when Christie’s approached both the EU Commission and the United States’ Department of Justice with proof of the agreement and applied for leniency in accordance with the relevant "whistle blowers" immunity scheme. (In the EU the 1996 Commission Leniency Notice has recently been updated, as discussed above).

As the investigation was only initiated because of Christie’s actions it was granted full immunity and escaped being fined. Sotheby’s was also co-operative throughout the investigation and accordingly its fine was reduced by 40%. However, because the agreement was considered to be "a very serious violation of Article 81(1)", it was still fined € 20.4 million (i.e. 6% of the company’s worldwide turnover).

Fifth highest company’s fine imposed on Nintendo for restricting parallel imports


In another Commission decision of 30 October 2002, the Japanese computer games manufacturer and seven of its European distributors were fined € 167 million, the fifth highest amount ever imposed for a competition law infringement.

During a seven year period it was discovered that these companies were preventing exports to high priced countries from low priced countries. This was because the price differences between EU countries varied considerably, with the UK being up to 65% cheaper.

The Commission found that each distributor was under an obligation to prevent parallel exports from its territory. Under the leadership of Nintendo they colluded to identify parallel exporters of the games, who were subsequently supplied with fewer products or completely boycotted.

Given the seriousness of the infringement and the harm caused to the end consumer, the Commission imposed very high fines. The highest fine was imposed on Nintendo because the company continued to operate

the system even after the investigation began.

Lufthansa/Austrian Airlines co-operation agreement exempted by Commission.

10/09/02 – OJ L242/25

On 5 July 2002 the Commission published a decision exempting a Co-operation Agreement between the European airlines Lufthansa and Austrian Airlines.

Lufthansa is one of the largest European airlines, ranking number two in terms of world traffic behind British Airways and just above Air France. Austrian Airlines is the fourteenth largest European carrier.

The long term objective of the Co-operation Agreement is worldwide integration of their networks. The area of principal concern for the European Commission was the proposal for the development of joint services for Austrian-German traffic.

The Commission found that the parties had a combined market share of 100% on 27 out of a total of 33 routes between Austria and Germany. These 27 routes account for more than 90% of total traffic between the two countries. Thus the parties were by far the strongest competitors on the Austrian – German air transport market.

Nevertheless, the Commission accepted the desirability of the rationalisation of the European transport industry and in particular that the merger of the complimentary networks provided by the parties would give rise to important synergistic effects. On the other hand, the Commission doubted whether the Co-operation Agreement ensured that consumers would share in the benefits of the expected costs savings, (e.g. through lower prices) and also that the Co-operation Agreement would lead to the elimination of competition on a number of routes between Austria and Germany.

The Commission appears to have accepted the parties argument that all European airlines could be considered potential competitors but only on the basis that perceived entry barriers were removed or reduced.

With this objective in mind, the Commission agreed to grant an exemption to the Co-operation Agreement until 31 December 2005, on condition that the parties accepted a number of conditions designed to assist in creating opportunities for new market entrants. In particular the parties have agreed to make available airport "slots" to new entrants, to limit the risk of selective price reductions to discourage new market entrants and to facilitate interline agreements with new entrants on a non-discriminatory basis.

Michelin fined for abusing dominant position

31/05/02 OJ L143/1

Infringement of Article 82: loyalty rebates & tying found to be an abuse

The Commission has ruled that Michelin (France) had abused a dominant position when it continued to apply a system of rebates and other price incentives designed to encourage customer loyalty.

Michelin, who was found to have 60% of the French market for replacement car tyres (twice the number of its nearest rival), set up a number of incentives that were seen as tying dealers to the company.

In setting the fine of € 19.76 million for the breach of Article 82, the Commission took into account the following as aggravating factors:

• the abuse had occurred over a period of more than 19 years;

• Michelin had already been fined for a similar infringement in Holland in 1981.

Court of First Instance

CFI rejects challenge to the Article 81(3) exemption granted to the Whitbread Partnership

Case T-131/99

Judgment of 21 March 2002, Shaw & Falla -v-Commission of the EC

In 1999 the Commission granted an Article 81(3) exemption to Whitbread in respect of the "Whitbread Pub Partnership" ("WPP") lease which contained a beer tie. In doing so the Commission accepted Whitbread’s evidence to show that tied tenants received countervailing benefits which compensated for the high tied prices they were required to pay for its beer.

A number of Whitbread tenants appealed the decision to the Court of First Instance (CFI) arguing that the Commission was wrong in relying upon the evidence supplied by Whitbread and should have investigated the position itself, seeking evidence from WPP tenants which would have shown that Whitbread had exaggerated the extent of the alleged benefits.

The CFI rejected the tenants’ application on the basis that the Commission had a wide discretion under Article 81(3) and there was no evidence of manifest error sufficient to amend the Commission decision.

CFI overturns Commission’s decision to block Tetra Laval / Sidel merger

Case Number T05/20

Following closely on the heels of its decision to reverse the Commission’s decision to block the Airtours/First Choice merger (as reported in our last newsletter), the CFI has once again overturned a Commission decision to block a merger.

Tetra Laval has been held to have a dominant position in its main market, comprising aseptic carton packaging and associated equipment for producing such packaging, used primarily for packaging fresh milk and fruit juice. In this merger Tetra Laval acquired the French company Sidel, which was a major producer of PET packaging equipment, used primarily to package water and carbonated soft drinks.

The Commission found that aseptic carton packaging and PET were two separate markets and that there was no significant overlap in activities between the merging entities. Despite this the Commission decided to block the merger on two grounds:

• that the merger might lead to the elimination of potential competition, as there were certain uses where carton and PET might in future become practical alternatives, (e.g. milk, juices, tea/coffee and fruit flavoured drinks).

• that the merger might lead to the creation of dominance in PET through leverage. The Commission considered that with advances in technology, there was an increasing likelihood that PET packaging would be offered as a substitute for cartons, thus leading to a substantial customer overlap. Tetra Laval’s dominance in the carton market might therefore spill over into the associated PET market, through the acquisition of Sidel.

In dealing with the elimination of potential competition argument, the CFI did not accept that the Commission had demonstrated a significant or growing competition between carton and PET that was sufficient to establish the existence of potential competition.

In relation to the leveraging for "spillover" argument, the CFI found that that would only be possible to establish if an eventual PET substitute for carton, applied to Tetra Laval’s existing carton customers, could be seen as a distinct market. On the facts, the CFI concluded that there was no evidence to suggest that any PET demand by such customers could not be met by suppliers of all forms of PET packaging, such as those supplying carbonated soft drink and water manufacturers. In the CFI’s view the presence of such competition would act as a disincentive to Tetra Laval seeking to exploit such leverage as it had.

UK Competition Law

OFT reaffirmes decision and fine on Aberdeen Journals Limited

Case CE1217/02

On 16 September 2002 the OFT reaffirmed its earlier decision of 16 July 2001 (press release 32/01) and fined Aberdeen Journals Limited ("AJL") € 1.328m for abusing a dominant market position in breach of the Chapter II prohibition.

The OFT decision found that AJL was guilty of predatory pricing when it sold advertising space in the Aberdeen Herald & Post at a loss with the intention of removing a rival from the market.

The earlier OFT decision found that Aberdeen Journals is dominant in the market for the supply of advertising space in local newspapers (paid for and free) within the Aberdeen area.

On appeal to the Competition Commission Appeals Tribunal ("CCAT"), this decision was set aside (as reported in our first newsletter), on the grounds that the market definition was not sufficiently reasoned. The CCAT referred the case back to the OFT.

After further analysis, the OFT has confirmed its original finding that the relevant market is the supply of advertising space in local newspapers within the Aberdeen area and reinstated the fine of € 1.328m. This was after a detailed review of the advertising market in Aberdeen. The OFT’s reasoning was based on the type of advertising medium that could be ‘substitutable’ for the service AJL provides.

The OFT said this fine reflected the ‘serious infringement of the Competition Act and should act as a deterrent to others’. This reflects the general position being set down by the OFT, which appears determined to be seen to be vigourously policing compliance with the Competition Act 1998.

Hasbro fined £4.95 million for price fixing


The OFT has fined Hasbro £4.95 million pounds for anti-competitive price fixing in breach of the Chapter I prohibition. When renewing its agreement with distributors in early 2001, Hasbro prohibited distributors from making settlements, retrospective rebates or ordinary discounts on Hasbro listed products, thus keeping prices high and interfering with freedom to compete. This form of agreement continued until July 2001, when Hasbro informed distributors by letter that they no longer had to keep to its wholesale list prices.

The OFT has ruled that the agreements breached the Chapter I prohibition of the Competition Act 1998, concerning agreements between undertakings which have as their object or effect the prevention, restriction or distortion of competition within the UK. The maximum penalty for such infringement is up to 10% of the offending company's turnover, but Hasbro was granted a 45% reduction on the original £9 million fine under the OFT's leniency programme, since it had co-operated fully with the OFT investigations and had asked for leniency at an early stage. Nevertheless, Hasbro's penalty of £4.95 million is the largest imposed to date under the Competition Act.

Ten distributors escaped fines, as the OFT found that the price fixing was put in place at Hasbro's initiative and, due to their substantially weaker economic position, the distributors had little choice but to comply.

Enterprise Act Update

The Enterprise Act received Royal Assent on 7 November 2002. The majority of its provisions come into force in May 2003. As outlined in our previous newsletter, it will have a profound effect on the administration and enforcement of national competition law in the UK. The new provisions in the Act attracting the most attention include:

Criminalisation of cartels

Following the lead of United States anti-trust law, the Enterprise Act creates a new criminal offence for persons who dishonestly agree that 2 or more undertakings will engage in any of the list of prohibited "hard-core" cartel activities, which include price-fixing, market sharing, limitation of production and bid-rigging. Such persons are liable to be punished by up to 5

years’ imprisonment or unlimited fines.

Disqualification of directors involved in cartels

The Enterprise Act also provided for disqualification, for a period of up to 15 years, of directors who knew, or ought to have known, of cartel behaviour.

Merger control

The Act changes the UK merger control regime by replacing the principal provisions of the Fair Trading Act 1973. The gross assets test will be replaced with a new turnover test. This new test will be met where the company being acquired has a UK turnover exceeding £45 million. The share of supply test will continue to be met where the combination of the purchaser and target's business leads to the merged entity controlling one quarter of the supply of goods or services in a relevant UK market. The system remains voluntary, so, where the tests are met, the parties can decide whether to notify the proposed (or completed) merger to the OFT.

The Act changes the substantive test for the assessment of mergers. It introduces a substantive lessening of competition test. This replaces the broader public interest test and heralds a new era of merger assessment based on competition economics. The test will be applied at both phases of a merger investigation, the OFT will apply the test in deciding whether to refer a merger to the Competition Commission for a phase two investigation. The CC will then apply the test to decide whether to clear the merger.

The Act depoliticises the merger control regime by removing the Secretary of State's power to make final merger decisions (except where national security or significant public interest considerations are raised). Upon a referral from the OFT, the CC will investigate and make a binding merger decision. As part of the process, the CC has been granted powers to address structural and/or behavioural remedies to the merging parties.

These changes are likely to come into force during Spring 2003 and until commencement the Fair Trading Act 1973 continues to apply.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on

Click to Login as an existing user or Register so you can print this article.

In association with
Up-coming Events Search
Font Size:
Mondaq on Twitter
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
Email Address
Company Name
Confirm Password
Mondaq Topics -- Select your Interests
 Law Performance
 Law Practice
 Media & IT
 Real Estate
 Wealth Mgt
Asia Pacific
European Union
Latin America
Middle East
United States
Worldwide Updates
Check to state you have read and
agree to our Terms and Conditions

Terms & Conditions and Privacy Statement (the Website) is owned and managed by Mondaq Ltd and as a user you are granted a non-exclusive, revocable license to access the Website under its terms and conditions of use. Your use of the Website constitutes your agreement to the following terms and conditions of use. Mondaq Ltd may terminate your use of the Website if you are in breach of these terms and conditions or if Mondaq Ltd decides to terminate your license of use for whatever reason.

Use of

You may use the Website but are required to register as a user if you wish to read the full text of the content and articles available (the Content). You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these terms & conditions or with the prior written consent of Mondaq Ltd. You may not use electronic or other means to extract details or information about’s content, users or contributors in order to offer them any services or products which compete directly or indirectly with Mondaq Ltd’s services and products.


Mondaq Ltd and/or its respective suppliers make no representations about the suitability of the information contained in the documents and related graphics published on this server for any purpose. All such documents and related graphics are provided "as is" without warranty of any kind. Mondaq Ltd and/or its respective suppliers hereby disclaim all warranties and conditions with regard to this information, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall Mondaq Ltd and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use or performance of information available from this server.

The documents and related graphics published on this server could include technical inaccuracies or typographical errors. Changes are periodically added to the information herein. Mondaq Ltd and/or its respective suppliers may make improvements and/or changes in the product(s) and/or the program(s) described herein at any time.


Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:

  • To allow you to personalize the Mondaq websites you are visiting.
  • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our information providers who provide information free for your use.

Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.

If you do not want us to provide your name and email address you may opt out by clicking here .

If you do not wish to receive any future announcements of products and services offered by Mondaq by clicking here .

Information Collection and Use

We require site users to register with Mondaq (and its affiliate sites) to view the free information on the site. We also collect information from our users at several different points on the websites: this is so that we can customise the sites according to individual usage, provide 'session-aware' functionality, and ensure that content is acquired and developed appropriately. This gives us an overall picture of our user profiles, which in turn shows to our Editorial Contributors the type of person they are reaching by posting articles on Mondaq (and its affiliate sites) – meaning more free content for registered users.

We are only able to provide the material on the Mondaq (and its affiliate sites) site free to site visitors because we can pass on information about the pages that users are viewing and the personal information users provide to us (e.g. email addresses) to reputable contributing firms such as law firms who author those pages. We do not sell or rent information to anyone else other than the authors of those pages, who may change from time to time. Should you wish us not to disclose your details to any of these parties, please tick the box above or tick the box marked "Opt out of Registration Information Disclosure" on the Your Profile page. We and our author organisations may only contact you via email or other means if you allow us to do so. Users can opt out of contact when they register on the site, or send an email to with “no disclosure” in the subject heading

Mondaq News Alerts

In order to receive Mondaq News Alerts, users have to complete a separate registration form. This is a personalised service where users choose regions and topics of interest and we send it only to those users who have requested it. Users can stop receiving these Alerts by going to the Mondaq News Alerts page and deselecting all interest areas. In the same way users can amend their personal preferences to add or remove subject areas.


A cookie is a small text file written to a user’s hard drive that contains an identifying user number. The cookies do not contain any personal information about users. We use the cookie so users do not have to log in every time they use the service and the cookie will automatically expire if you do not visit the Mondaq website (or its affiliate sites) for 12 months. We also use the cookie to personalise a user's experience of the site (for example to show information specific to a user's region). As the Mondaq sites are fully personalised and cookies are essential to its core technology the site will function unpredictably with browsers that do not support cookies - or where cookies are disabled (in these circumstances we advise you to attempt to locate the information you require elsewhere on the web). However if you are concerned about the presence of a Mondaq cookie on your machine you can also choose to expire the cookie immediately (remove it) by selecting the 'Log Off' menu option as the last thing you do when you use the site.

Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies and we are not aware of any at present that do so.

Log Files

We use IP addresses to analyse trends, administer the site, track movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.


This web site contains links to other sites. Please be aware that Mondaq (or its affiliate sites) are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of these third party sites. This privacy statement applies solely to information collected by this Web site.

Surveys & Contests

From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information requested. Information requested may include contact information (such as name and delivery address), and demographic information (such as postcode, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the functionality of the site.


If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Mondaq stores this information and may contact the friend to invite them to register with Mondaq, but they will not be contacted more than once. The friend may contact Mondaq to request the removal of this information from our database.


This website takes every reasonable precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected using firewalls and other security technology. If you have any questions about the security at our website, you can send an email to

Correcting/Updating Personal Information

If a user’s personally identifiable information changes (such as postcode), or if a user no longer desires our service, we will endeavour to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the “Your Profile” page or by sending an email to

Notification of Changes

If we decide to change our Terms & Conditions or Privacy Policy, we will post those changes on our site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

How to contact Mondaq

You can contact us with comments or queries at

If for some reason you believe Mondaq Ltd. has not adhered to these principles, please notify us by e-mail at and we will use commercially reasonable efforts to determine and correct the problem promptly.