In the UK, if a company is found to have breached competition law and a director was involved in the wrongdoing (or should have been aware of it), a court order can be sought disqualifying a director from acting as a director of any company for up to 15 years. Any breach of competition law can lead to a director disqualification order. These powers are on top of penalties that may be imposed on the company itself, such as fines, and criminal penalties that can be imposed on individuals. The Competition and Markets Authority (CMA) has published guidance on competition disqualification orders. In addition, the CMA has jointly published with the Institute of Risk Management updated guidance on competition law risk for managers, directors and their advisors. The updated guidance features case studies, examples of best practice and forewords indicating the CMA's updated approach to competition infringement detection and enforcement. The CMA notes, in the updated guidance, that it will now consider disqualifications in all cases of competition law infringement. For a tracker on the cases where

This Practice Note provides a list of sample questions that can be used in a corporate transaction due diligence exercise to identify and prompt disclosure of any competition law issues affecting the business being acquired and to request relevant documents. In the sample questions listed below, [seller] includes its corporate group and references to the activities of [business] are to the activities of the target group, including all subsidiaries and business units being acquired. It may be necessary to tailor the wording to reflect the actual entities and businesses being acquired and the nature of the corporate transaction. Note—requests for documents and information should be read subject to applicable legal privilege, confidentiality and statutory disclosure restrictions. Sample questions • Please provide details and copies of any contract, practice or arrangement of the [seller] in relation to the [business] which infringes or falls within the scope of Article 101 TFEU, the Chapter I prohibition of the Competition Act 1998 or any equivalent competition law worldwide, and details of any unilateral conduct of the [business] which infringes or falls within

This document aims to track and summarise legislation, guidance, decisions and other policy developments which help reveal the approach of global competition authorities in tackling competition law issues (ie wage-fixing and no-poach agreements etc) in labour markets. 2026 Jurisdiction and body Details Developments Office of Competition and Consumer Protection (Poland) The UOKiK imposes fines totalling PLN 571,960,550 on Jeronimo Martins Polska S.A., 29 transport undertakings, and eight individuals for entering into no-poach agreements that restricted competition in the labour market • Press release published—14/09/2026 Office of Competition and Consumer Protection (Poland) The UOKiK confirms carrying out inspections in numerous sectorsThe UOKiK suspects that the companies involved may have entered into (among other things) no-poaching agreements • Press release published—10/06/2026 Poland (Office of Competition and Consumer Protection) The UOKiK confirms carrying out inspections in the transport/logistics for retail services sectorThe UOKiK suspects that the companies involved may have entered into (among other things) no-poaching agreements • Press release published—02/06/2026 Poland (Office of Competition and Consumer Protection) The UOKiK confirms carrying out inspections in the transport/logistics for retail services sectorThe

Note that additional commentary on the issues discussed in this Practice Note in the context of the regulation, consenting and incentivisation of the net zero energy transition is available in the following textbook that we have published: Collinson and Hockman on Energy Law: Regulating, Consenting and Incentivising the Energy Transition. Quick links If you are only interested in certain aspects of the evolving GB competition in transmission regime, you may find the following links to particular sections of this Practice Note useful: • The existing position • The CATO mechanism • The SPV model • The Competition Proxy model • The Hinkley-Seabank project Introduction The Great Britain (GB) network of onshore electricity transmission lines have (since privatisation) been owned, maintained and improved by three licensed transmission system owners (TOs). These owners took the form of three privately-owned companies: National Grid Electricity Transmission plc (NGET), in respect of the transmission lines located in England and Wales, SP Transmission PLC (SPT)

Preliminary considerations An offeror or potential offeror will need to consider at the outset of the offer process the impact of any competition law issues on the timetable and conduct of the offer. Preliminary issues will include: • determining which competition authority has jurisdiction • agreeing what merger control conditions should be included: this will be determined or influenced by the relevant merger control requirements and Takeover Code (Code) obligations, but tactics and strategy may also come into play • agreeing the amount and quality of information which the offeror can expect from the offeree and the degree of its cooperation with the regulatory process: this is likely to be influenced by whether the offer is recommended or hostile and the likelihood of a competing bidder emerging Which competition authority has jurisdiction? Even after the end of the Brexit transition period on 31 December 2020 (IP completion day), the EU’s merger control regime continues to apply to UK undertakings—as with any undertaking operating globally, if a transaction satisfies the EUMR jurisdictional thresholds, clearance from the

means the national and directly effective supra-national legislation of any jurisdiction which governs the conduct of companies or individuals in relation to restrictive or other anti-competitive agreements or practices and the control of acquisitions and mergers (including, but not limited to, the Chapter I and Chapter II prohibitions under the Competition Act 1998, the prohibitions in Article 101 and Article 102 TFEU and the cartel offence in Part 6 of the Enterprise Act 2002, as amended) and includes reference to antitrust law as appropriate

ARCHIVED: This archived Practice Note explores the competition implications of using agency as a commercial model. It was written with the previous Vertical Restraints Block Exemption Regulation 330/2010 and 2010 Guidelines in mind—these have been replaced by the Vertical Block Exemption Regulation 2022/720 (VBER 2022) and 2022 Guidelines on Vertical Restraints (2022 Guidelines) respectively. This Practice Note is not maintained and is for background information only. For an assessment of agency under Article 101 TFEU, the VBER 2022 and the 2022 Guidelines, please see the relevant sections within Introduction to the application of Article 101 TFEU to vertical agreements, The Vertical Block Exemption Regulation 2022/720 and Analysing vertical agreements outside the Vertical Block Exemption Regulation 2022/720 There are several ways in which a supplier can distribute its product. A supplier may: • distribute products or services itself • use a distributor, or • use an agent. In making this decision, a supplier will inevitably be influenced by a variety of commercial considerations. Alongside such commercial considerations, a supplier will also have to consider EU

This document aims to track and summarise legislative, guidance and other policy developments which help reveal the approach of global competition authorities in tackling the issue of how algorithms and artificial intelligence (AI) may give rise to competition law concerns. 2026 Jurisdiction and body Details Developments Denmark (Danish Competition and Consumer Authority) Visma Dinero, an accounting services provider, stops the release of its new AI assistant in Denmark, after the DCCA told it that information exchange between competitors via the latest version of its tool might harm competition • Press release issued—21/05/2026 South Korea (Korea Fair Trade Commission) KFTC launches a market study into the AI services sector • Market study launched—21/05/2026 Turkiye (Turkish Competition Authority) The TCA launches a sector inquiry into AI to assess how control over data, computing power and ecosystems may reshape market power and create competition risks • Study launched—08/04/2026 India (Competition Commission) The CCI issues a guidance note advising companies to undertake self-audits of their AI systems • Guidance note published—March 2026 South Korea (Korea Fair Trade Commission) KFTC launches a study into AI service bundling

This document aims to track and summarise legislative, guidance and other policy developments which help reveal the approach of global competition authorities in tackling the issue of how blockchain technology may give rise to competition law concerns. 2023 Jurisdiction and body Details Developments Luxembourg (Autorité de la concurrence) The Autorité de la concurrence launches a market study into the blockchain sector • Press release published—06/06/2023 2021 Jurisdiction and body Details Developments France (Autorité de la Concurrence—AdC) Following the launch of its Fintech inquiry in 2020, the AdC published its findings which includes a discussion of (amongst other things) the competition law risks that may arise from the use of blockchain technology • Public opinion published—29/04/2021 India (CCI) Discussion paper which aims to

There are generally three principal categories of provisions in the transaction agreement (eg sale and purchase agreement) that will need to be considered from a competition law perspective: • merger control conditions to closing • competition warranties; and • non-compete covenants For the purposes of this Practice Note, the individual parties are referred to as 'seller' and 'buyer' (though similar considerations will generally be relevant to the parties to a joint venture). For examples of clauses that can be used in a sale and purchase agreements, see further: Standard competition law clauses for sale and purchase agreements. Note—if an offer is made for a target (or potential target) company that has securities that are admitted to trading on a regulated market or a multilateral trading facility in the UK or on any stock exchange in the Channel Islands or the Isle of Man then the Takeover Code may apply (see further, Merger control and the Takeover Code). For more information on the competition law issues to consider during a corporate transaction, see further, Competition

This Checklist summarises the competition law considerations relevant to corporate transactions. Preliminary considerations Before you make contact with the other side, it is important to: • put together a team to work on the transaction and establish communication channels with all relevant parts of the business. It may be necessary to engage specialist advisors, depending on any PR issues or anticipated complexity or regulatory issues, for example: ◦ lobbying/PR specialists ◦ economists ◦ accountants • exercise caution regarding document creation (both internal and external) and public and internal statements • manage expectations, including in relation to any potential competition concerns and preliminary timing considerations • confirm that the contemplated transaction has a legitimate purpose • consider the maintenance of legal privilege in relation to communications where relevant (see further, Legal privilege in EU competition cases) Issues before and during negotiation There are a number of issues to be aware of as soon as transactions are contemplated and during negotiations, not least to ensure there can be no risk of collusion during negotiation

What is the background to competition in the UK energy sector? This Practice Note deals with the UK energy sector, including the electricity and (downstream) gas markets but also other areas which have been included within the responsibilities of the regulator; namely, the Gas and Electricity Markets Authority (GEMA), acting through its administrative office, the Office for Gas and Electricity Markets (Ofgem). For more information on Ofgem, see Practice Note: Ofgem. As the UK’s energy markets have evolved—particularly to address the challenges of decarbonisation and achieving net zero emissions by 2050—Ofgem has gained a range of additional responsibilities. Most recently this has included responsibilities for regulating heat networks and carbon capture, usage and storage (CCUS). In this Practice Note, references to the market or markets are to the gas and electricity markets (unless otherwise stated). GEMA was established by Utilities Act 2000 (UA 2000), although its powers and duties are set out in various other statutes. In the case of electricity and gas markets,