Hogan Lovells Publications | Global Regulatory Alert | 07 November 2019

Information exchange between competitors – Hong Kong Competition Commission publishes decision on proposed pharmaceutical sales survey

On 22 October 2019 the Hong Kong Competition Commission published a decision ruling that a sales survey proposed by the Hong Kong Association of the Pharmaceutical Industry is not exempt from the Competition Ordinance.

The decision provides guidance for market players beyond those active in the pharmaceutical sector. On a substantive level it gives some insights into the authority's thinking on information exchange between competitors. From a procedural viewpoint, the decision sheds light on the application process for associations or companies to obtain an "exemption decision" from the authority.

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