GREECE Law and Practice Contributed by: Anna Manda and Maria Kallidopoulou, Karatzas & Partners
• at the HCC’s own initiative (ex officio investi - gations); • following a complaint by a third party; or • following a leniency application. The HCC is legally bound to consider all com - plaints legally filed. However, under the HCC’s prioritisation system, the HCC must investigate pending cases according to their ranking on the basis of the point system. In practice, the HCC focuses its enforcement resources on cases with the highest likelihood of significantly impacting competition in the market and leading to con - sumer harm. Low-ranking complaints can be rejected by the HCC by summary decisions, informing the complainants of the reasons for not pursuing their complaint. As regards the complaints that satisfy the prior - ity criteria, the president of the HCC introduces the case before the HCC. A rapporteur is then appointed, who will be in charge of the case and who will prepare the statement of objections. 2.2 Dawn Raids/Search Warrants The HCC has wide investigative powers, which mirror the investigative powers enjoyed by the EC. Notably, the HCC can inspect business premises (dawn raids). In addition, the HCC can conduct inspections of the private property of directors, managers and other staff members of the undertaking concerned, provided that a court warrant is issued and a public prosecutor is present. Dawn raids are very common in practice and, during the past couple of years, the number of dawn raids performed by the HCC has drasti - cally increased. By way of example, during the course of 2024 and up to the end of April 2025, the HCC performed eight dawn raids. Notably, the HCC has recently carried out dawn raids at
the premises of undertakings active in the fol - lowing sectors: • maritime transport; • coffee, chocolate, and infant nutrition; • pet food; • ferry services; • waste management; • smart water meter systems; An outside counsel can be present during the dawn raid, but this is not a prerequisite for the legality of the inspection, and the HCC is not obliged to wait for the outside counsel before it enters the relevant premises and commences the inspection. Powers of HCC Inspectors During a dawn raid, the authorised HCC officials enjoy the powers of tax auditors. More specifi - cally, HCC officials have the power to: • IT; and • travel. • inspect books, records and other documents of the undertaking concerned, and make cop - ies thereof; • seize, receive or obtain copies of books and documents; • inspect and collect information and data from mobile terminals and portable devices and their servers and the cloud computing located inside or outside the premises of the under - taking concerned; • seal any professional premises, books or documents; and • take sworn or unsworn witness state- ments and ask for explanations of facts or documents relating to the subject matter of the inspection, and record the respective answers.
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