There has been a clear upsurge of antitrust dawn raid activity in the EU since a couple of weeks (map below) in a wide range of sectors.  With the summer break over for antitrust officials throughout the EU,  now would be a good time to dig up and revise those antitrust dawn raid manuals, in particular the emergency contact details of your company’s listed dawn raid team members.

Even if you are certain that your company is “100% compliant”, companies can and do get subjected to invasive antitrust investigations as a result of the conduct of third parties over which they have no or little control.

Personnel, company structures, product  markets, competitors and business relationships change and compliance programmes need to be regularly reviewed and adapted in order to keep them both effective and relevant to the company’s changing environment. 

Few on-site compliance managers would be happy with discovering during the onset of a dawn raid that their dawn raid manuals are of no actual help as with the passing of time the personnel structure of the company has changed and the listed contact details of the dawn raid internal and external team members are no longer valid.

If nothing else this week, have someone call your in-house dawn raid team leaders and the external dawn raid assistance lawyers listed in your manuals to check that their telephone numbers and other contact details are still correct.



Note: Map data based on reported dawn raids in consulted public press resources.