Response to CMA Consultation - Guidance on Applications for Leniency in Cartel Cases

The Committee's comments are based on our members' significant experience in engaging with the CMA's leniency regime, and other leniency regimes in key jurisdictions. Our response focuses on ways to ensure that leniency remains effective and sufficiently attractive to potential applicants, such that the regime can continue to play an important role in the CMA's strategy to deter anticompetitive conduct by supporting and facilitating the detection of and enforcement actions against cartel activity. We also take note of the CMA's new overarching framework for engaging with businesses: Pace, Predictability, Proportionality and Process (the "4 Ps").