GREECE Law and Practice Contributed by: Anna Manda and Maria Kallidopoulou, Karatzas & Partners
• written requests issued by the HCC for infor - mation to be provided; • inspection orders; • the initiation of proceedings in relation to the infringement; • the assignment of the case to a rapporteur; and • the notification of a statement of objections. The limitation period will recommence following each interruption. In any event, the limitation period for the imposition of fines by the HCC cannot exceed ten years, provided that the HCC has not imposed any fines by that time. Finally, the limitation period will be suspended while the HCC’s decision or a court’s decision is pending. 1.6 Jurisdiction The GCA applies to all restrictions of competition that affect or might affect the Greek market, even if these are due to agreements between under - takings, decisions by associations of undertak - ings, concerted practices between undertakings or associations or concentrations of undertak - ings, or unilateral actions implemented or taken outside Greece or by undertakings or associa - tions of undertakings that have no establishment in Greece. 1.7 Principles of Comity Principles of comity are neither established nor applied under Greek competition law. 1.8 Enforcement Priorities Cartel enforcement by the HCC has significantly increased during the past few years. The HCC is conducting a large number of dawn raids every year covering a variety of sectors (see also 2.2 Dawn Raids/Search Warrants ). Thus far, the vast majority of the cases under examination by the HCC concern domestic cartels.
In terms of the practices under the HCC’s radar, the HCC is increasingly looking into price fix - ing and bid rigging practices, as well as vertical agreements. 1.9 Guides Published by Governmental Authorities Τhe HCC has published the following written guidelines relating to cartel conduct: • practical guidance concerning the application of the GCA (available in Greek only); • interpretative guidelines on the method of setting fines (available in Greek only); • a notice on the handling of complaints for competition law infringements (English ver - sion); • HCC decision on the terms, conditions and relevant procedure for the acceptance of commitments (English version); • HCC decision on leniency programme (avail - able in Greek only); • HCC decision on settlement procedure (avail - able in Greek only); • guidelines for the application of Article 1A of the GCA (available in Greek only); • guide to competition law for associations of undertakings (available in Greek only); • guide to promoting and enhancing competi - tion in public policy planning (available in Greek only); and • guide to competition in the agricultural sector (available in Greek only).
2. Early Stages of Cartel Enforcement 2.1 Initial Investigation Investigations can be initiated:
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