We would like to present the overview of the most important legislation changes in competition for 2016.
In contrast to 2015, which was marked by the adoption of the "fourth antimonopoly package"1, the past year was not notable for such global changes of antimonopoly regulation, except perhaps for certain sectors of the Russian economy, with the most significant new developments affecting retail. 2016 was the first year when the new antimonopoly rules introduced by the "fourth antimonopoly package" were effective. Some of them (such as, for example, the rules for nondiscriminatory access to products manufactured and/or sold by dominant undertakings whose share of the market exceeds 70 percent) did not manifest themselves much over the past year in the enforcement practice, while others are being applied to the full extent by both the regulator and business entities. These include such novelties as the introduction of internal appeal at the Federal Antimonopoly Service ("FAS"); expanded use of the "warnings" issued to presumed law offenders by FAS before initiating an antimonopoly case; the requirement to obtain prior consent to the entry into agreements on joint activities in the Russian Federation between competitors; as well as the FAS Presidium exercising powers to issue clarifications on applying the legislation on the protection of competition. On the whole, the year was rich in various types of clarifications or guidelines. In addition to the clarifications of the FAS Presidium, the RF Supreme Court Presidium also issued an overview of court practice in antimonopoly law this year.
Radical changes to the Retail Law and subsequent FAS clarifications
Pharmaceutical industry Best Practices Code
FAS Presidium clarifies a number of important practical issues of applying antimonopoly legislation
Amendments softer on small business
Radical changes to the Retail Law and subsequent FAS clarifications
On July 3, 2016 amendments2 to the Retail Law3 were adopted that obligated manufacturers, retailers and distributors of food products to review their existing contractual relations and develop new legal forms of cooperation. The changes to the Retail Law entered into force on July 15, 2016. Supply contracts concluded before that date should have been brought into compliance with the new requirements by January 1, 2017. From now on, the terms of contracts contravening the amended Retail Law shall lose their validity.
Key changes in the legal regulation of retail food product markets include a decrease in the total consideration payable by food product suppliers to their customers (including retail chains and distributors) from 10% to 5% of the price of the food products purchased. The maximum total consideration will from now on include not only consideration connected with purchasing a certain volume of food products, but a fee for providing "product promotion services" (for which a special definition has been introduced), logistical services, services to prepare, process and package goods and other similar services. VAT and excise are not included when calculating the total amount of consideration. Suppliers are prohibited from paying retail chains other types of consideration not contemplated by the Retail Law. Product promotion services, services to prepare, process and package goods and other similar services should be documented in a separate contract.
Other major changes are the reduction of time limits on deferred payment for the supply of food products and the mandatory provision by retailers and suppliers of access to information on the terms for selecting contracting parties to enter into food product supply contracts, the material terms of the contract, and (for suppliers) the quality and safety of the products being supplied by posting that information on a website (previously the information could be sent upon request), and a number of other changes.
The extensiveness of the amendments and the ambiguity of the legislative language have caused some concern and a large number of questions among both experts and the business community. This has required a reaction from FAS, which voiced its attitude to the issues of concern of the updated Retail Law in the form of clarifications addressed to participants of the food retail market.
In 2016 FAS published two packages of clarifications (the "Clarifications") on applying the new provisions of law. Although in preparing the Clarifications FAS did a lot of work discussing and clarifying with market participants and the expert community how to apply the new provisions of the Retail Law, a number of thorny questions require further clarifications. In particular, FAS explained that if product promotion services, logistical services, services to prepare, process and package goods and other similar services are provided to the supplier by independent contracting parties, i.e., by entities not engaging in retail activity and not in those entities' group of persons (for example, by independent advertising and logistics companies), the limit on total consideration does not apply (provided there is no "imposing" or "coercing" into concluding such contracts by the purchaser of the goods, especially, by retail chains). However, in the Clarifications FAS has not given an answer to the important question of whether the 5% limit applies if product promotion services and other similar services are provided by a retail chain not to the supplier (for example, to the distributor) but to a third party with which the chain does not have a supply contract (for example, the manufacturer that is directly interested in promoting its products but sells them through a network of distributors).
In FAS' opinion, the fee for services should be determined not as a percentage of the cost of delivery, but in a fixed amount. Otherwise, i.e., if the retail chain sets the price of the product promotion services contract as a percentage of product turnover, then, in the regulator's opinion, that would result in discrimination by the chain against the suppliers.
The Clarifications also consider the opposite situation, when discriminatory conditions, which are understood to mean "an unconditional unequal position of some contracting parties as compared with others, other conditions being equal" may be created by food product suppliers toward retail chains. Thus, FAS clarified that in principle suppliers are allowed to set different conditions for the supply of goods (including different prices for the same products); however, those conditions should not be discriminatory. At the same time, in the regulator's opinion discrimination will occur when the supplier has no objective basis to set different prices for the same product, which basis can be documented in the relevant "pricing" or "discount" policies, "discount matrix," "price formula" and other similar documents and contractual provisions objectively and transparently stipulating the price differences for different retail chains.
In the Clarifications FAS also reveals its position on a number of other topical questions: (а) the supplier is allowed to use so-called "promotional" or "sale" discounts, provided the "discount is translated to the shelf", i.e. equally reduces the shelf price; (b) the basis for calculating the total consideration should be the price at which the contracting party actually acquired the food product, i.e., the price with all applicable discounts; (c) it is prohibited to provide a discount on a product after ownership of the product has passed to the purchaser (i.e., after delivery), unless the parties agreed on such discount (the procedure for calculating it and the terms for providing it) when they entered into the supply contract, etc.
We note that the Clarifications are for information and recommendation purposes and are not binding, which in principle allows for the possibility of a different interpretation of the provisions of the Retail Law by some FAS officers (in particular, in the territorial departments) in their practice of applying the law.
Pharmaceutical industry Best Practices Code
In addition to retail, important changes occurred in regulation or, more precisely, self-regulation of the pharmaceutical industry: the "Pharmaceutical Industry Best Practices Code" developed at FAS' initiative and under the aegis of the Health and Pharmaceuticals Committee of the Association of European Businesses (the "Code") was published on April 19, 2016.
The Code essentially represents a set of rules to guide pharmaceutical manufacturers and/or official importers of pharmaceuticals (participants in the Code) in evaluating whether their conduct vis a vis customers (distributors, government customers and pharmacies) is permissible. The Code is binding only on those who have voluntarily adhered to it by signing a declaration to this effect. It should be acknowledged that the Code proposes slightly more lenient approaches to different realities of the pharmaceutical business than could have been expected relying on the general trends of enforcement practice. The Code's adoption clearly evidences the growing role of soft law in Russian antitrust regulation.
According to the Code, each participant should develop commercial policies governing the procedures for its interaction with customers and including, in particular, criteria for selecting distributors, a procedure and timeframe for decision-making on whether or not to enter into a contract with a potential distributor, a standard contract including the basic terms for product supply, a procedure and mechanism for providing discounts/bonuses, etc. The Code recommends partial publication of the commercial policies by posting their "basic provisions" on the participant's official site.
In addition to the general criteria for selecting distributors that are aimed at confirming a potential contracting party's legal capacity, financial soundness and business reputation, the Code empowers participants when selecting distributors to take account of "documented facts" that the customer has violated the standards of national and/or international/foreign anticorruption legislation, including the US Foreign Corrupt Practices Act and the UK Bribery Act.5 The participant can also limit, for economic or technological reasons, the maximum number of distributors based on the specifics of its business model. In such a case the participant must include in its commercial policies provisions ensuring a transparent, public and nondiscriminatory procedure for selecting distributors on a competitive basis. A Code participant may set in the commercial policies a minimum one-time shipment volume and a minimum purchasing volume during a specific time period, both in quantitative and monetary terms. If the customer fails to comply with these conditions, the participant will have the right to terminate the contract.
At the same time, the Code establishes that participants' application of different terms of cooperation with different customers may be justified depending on such criteria as purchasing volume, payment procedure, product shelf life, distribution channel (public or commercial purchasing), experience of cooperation and others. For example, the Code establishes that participants have a right to apply discounts and bonuses on a nondiscriminatory basis, in particular, based on such criteria as reaching a certain purchasing volume in quantitative or monetary terms, or entering into a contract with a government customer. At the same time, the Code does not touch on many other grounds for providing discounts (bonuses, rewards) that are widely used by pharmaceutical companies but have not yet been clearly evaluated in the law enforcement practice, for example, bonuses to specific customers or in a specific region for sales growth, seasonal discounts, etc.
If the purpose of the agreement is to localize the participant's production in the Russian Federation, then the participant may enter into exclusive agreements with the customer by concluding supply contracts for bulk medicines for subsequent manufacturing of medicinal products in Russia, and processing (tolling) agreements. Such provisions seem justified as they will allow the Russian contracting party of the Code participant to protect its own investments once production is launched by exclusively determining the strategy for selling the products. The Code also empowers a participant to set a maximum resale price for the entire supply chain from the distributor to the pharmacy.
According to the Code, a participant may decide to take part in procurement to supply its own products to a government customer directly and, in such case, refuse to supply to a distributor. In doing so it may not refuse to supply to a distributor who has expressed the desire to take part in the procurement, provided the participant has an obligation to supply products to the distributor that arose before the participant decided to take part in the procurement directly. It would seem that this provision heeds the position of the RF Supreme Court set out in the Ruling6 on the Teva Pharmaceutical Industries Limited case. In that case the court declared unjustified a manufacturer's refusal to supply goods to a distributor because it had decided to take part in the procurement directly, including because the manufacturer and the distributor had already concluded a contract and the manufacturer had unfulfilled its obligations to supply the products to the distributor.
FAS Presidium clarifies a number of important practical issues of applying antimonopoly legislation
The "fourth antimonopoly package" empowered the collective antimonopoly authority bodies to give clarifications on applying antimonopoly legislation based on materials from examining and summarizing the practice of its application by the regulator. Exercising these powers, in 2016 the FAS Presidium developed and published several clarifications, each of which is devoted to a particular aspect of antitrust regulation. These clarifications are non-binding, but business entities should be well aware of the clarifications because most likely FAS will follow them in its practice of applying the laws. Let's take a look at the most important clarifications adopted by the FAS Presidium in 2016.7
Clarification No. 1 "Determination of a Monopolistically High and Low Product Price"8 mostly sums up FAS' practice that has developed as of today with respect to using the cost method and the comparable markets method when analyzing whether a price set by a dominant entity is justified.
For example, FAS draws attention to the fact that the comparable markets method should first be used when analyzing a price set by a dominant entity. In other words, it should be determined whether there is a competitive market that is comparable with the market on which the dominant entity operates in terms of customers or sellers of the product, conditions for circulation of the product, conditions for accessing the product market, state regulation, including taxation and customs tariff regulation. A product price cannot be considered monopolistically high if it does not exceed the price formed in competitive conditions on such comparable product market, regardless of the amount of costs to manufacture and distribute the product and the profit earned by the undertaking.
It is possible to determine a monopolistically high or low price using the cost method alone if there is no comparable product market. When using the cost method, primarily costs required to manufacture and sell the product, profit from sale of the product and the product price set by a specific dominant entity should be analyzed.
The clarification is useful as a kind of summary of the approach to analyzing the justifiability for prices set by dominant entities. However, it is not exhaustive, and rightly so, as the specifics of the market in question should be considered in each particular instance.
Clarification No. 2, "'Vertical' Agreements, including Dealer Agreements"9 provides a general definition of "vertical" agreements and points to the following specifics of classifying such agreements:
- An agreement between a manufacturer and a distributor should also be considered "vertical" if the parties sell the product on the same product markets (for example, if the manufacturer sells the product both through a distributor and independently), but the distributor does not manufacture products that are interchangeable with that manufacturer's products, or sells interchangeable products of various manufacturers.
- Prohibited terms of a "vertical" agreement may be in both verbal and written forms, and the entry into a written agreement does not rule out the Competition Law being applied to verbal arrangements containing anticompetitive terms.
- If an agent enters into a product supply contract or sale-purchase contract on behalf of a principal, then it is precisely one of those contracts and not the agency agreement that will be considered the "vertical" agreement.
- The entry into intragroup "vertical" agreements to which the prohibitions on anticompetitive agreements do not apply does not mean that other restrictions of the Competition Law cannot be applied to them, in particular, the prohibition on discriminating against purchasers who are not in the dominant seller's group.
The clarification also describes certain features of prohibited "vertical" agreements. In particular, it is mentioned that fixed or minimum prices represent prohibited forms of setting the resale price for a product. However, the clarification does not touch on the issue of the legality for setting recommended resale prices. Based on the enforcement practice that has developed thus far, it may be assumed, with some reservations, that recommended prices at which the seller proposes that the customer resell the product are generally not prohibited. However, recommended prices should not be de facto binding, in particular, a "vertical" agreement should not stipulate any adverse consequences for the customer for failing to comply with those prices (for example, loss of bonus, suspending/stopping supplies, etc.).
We note specifically that the clarification acknowledges that agreements between car manufacturers and dealers that meet all of the criteria of the Code of Conduct of the Automobile Manufacturers Committee of the Association of European Businesses governing certain aspects of relationships between car manufacturers and distributors, official dealers and independent service stations in the automotive sector are allowed. It would be logical for FAS to apply a similar approach to "vertical" agreements that meet all of the criteria of the European Business Association's Pharmaceuticals Industry Best Practices Code, which was published after this clarification was developed.
Clarification No. 3 "Proving Prohibited Agreements (including Cartels) and Concerted Practices on Product Markets, including in Auctions"10 lists the main types of agreements and concerted practices prohibited by antimonopoly legislation, which in itself can be useful as a reminder for business entities' employees.
Describing the specifics of proving these antimonopoly violations, FAS states that the fact that an anticompetitive agreement (including a verbal one) has been entered into may be established based on the circumstantial evidence alone (for example, lack of economic justification for the conduct of one of the parties to the agreement creating an advantage for another party to the agreement; the auction participants' use of the same IP address (user account) to file online auction bids; the parties to the agreement actually being located at the same address; the parties to the agreement having payments to one another evidencing a mutual interest in the outcome of implementing the agreement, etc.), in other words, even without a single piece of direct evidence. In confirmation of this finding FAS cites the decision of one of the courts: "in order to establish that there is an anticompetitive agreement it is necessary to analyze a number of pieces of circumstantial evidence, juxtaposing each of them with other pieces of evidence and not encumbering the proof process with the mandatory need to search for at least one piece of direct evidence. A totality of indirect evidence of an agreement and/or concerted practices (if not proven otherwise) may play a decisive role in proof." In our view, in practice, building the body of evidence on circumstantial evidence alone often results in the regulator issuing less than convincing decisions which, nonetheless, are often upheld by the courts.
Clarification No. 5 "Evaluating the Permissibility of Business Methods of Entities Dominant on a Product Market"11 concentrates on instances and criteria for permissibility of certain actions (omissions) that are prohibited by the Competition Law as abuse of dominance. In particular, the clarifications touch separately on the issue that the permissibility criteria contemplated by Article 13(1) of the Competition Law may be applied, inter alia, to actions to abuse dominance that are not explicitly listed in Article 10(1) of the Competition Law.
The clarification specifies that conduct complying with the rules of nondiscriminatory access to the services of natural monopolies approved by the Russian Federation Government is permissible and points to favorable results of applying the rules that have already been adopted. FAS also reminds readers that the Russian Government has the authority (received as a result of the entry into force of the "fourth antimonopoly package") to approve rules of nondiscriminatory access to products manufactured and/or sold by dominant undertakings whose share of the market exceeds 70 percent that are not natural monopolies. We note that no such document has been approved by the RF Government to date.
Finally, in its clarifications FAS advocates that dominant business entities approve "trade practice rules" and list the provisions that should be contained in such practices. In the regulator's opinion, this will evidence to contracting parties that a dominant entity is transparent and will serve to prevent possible abuses by the dominant entity, primarily in the form of creating discriminatory conditions for consumers. At the same time, FAS acknowledges that (at least absent a case-related prescription to this effect) the adoption of trade practices by business entities and sending them to FAS for approval is voluntary.
It would seem an important strategic concession by the antimonopoly authority that trade practice rules approved by FAS will allow business entities to take actions covered by the rules without worrying about antimonopoly prosecution. The regulator calls on business entities to remain vigilant, as, if a dominant entity takes actions contrary to the Competition Law, then such actions may be considered by the antimonopoly authority for possible violation of Article 10 of the Competition Law regardless of whether there are trade practice rules approved by FAS in place.
Clarification No. 6 "Proving and Calculating Damages Caused by Violation of Antimonopoly Law"12 was developed by FAS in order to encourage persons aggrieved by antimonopoly violations to file suit in court against violators for recovery of damages. In contrast to foreign states, today Russia has few such court suits.
According to the clarification, in order to recover damages from an antimonopoly law violator the claimant must prove:
- that antimonopoly law was violated;
- that there were damages (including their amount);
- a causal relationship between the antimonopoly law violation and the damages caused.
An antimonopoly law violation is generally established to have occurred on the basis of a FAS decision in an antimonopoly violation case. The situation is more complex for calculating damages, as it is not always possible to easily calculate them without risking losing the basis of the causal relationship between the antimonopoly law violation and the damages if stating larger amounts.
The clarification cites examples from the scant practice explaining how one can reasonably calculate damages depending on the specifics of the antimonopoly violation (various forms of abuse of dominance, unfair competition related to the acquisition and use of exclusive rights to a trademark, a government authority taking anti-competitive actions).
In addition, FAS justifiably refers to the position of the Plenum of the RF Supreme Court according to which a claim for damages cannot be denied merely on the ground that it is impossible to determine the precise amount. In this instance the amount of damages to be recovered is determined by the court in light of all of the facts of the case, based on the principles of fairness and that liability be commensurate to the violation.13
The clarification generally has practical value as a summation of the current practice of recovering damages caused by an antimonopoly law violation, and is intended to encourage the spread of such types of suits in Russia.
RF Supreme Court Presidium approves Overview of Court Practice in the Consideration of Competition Protection Cases
On March 16, 2016, the RF Supreme Court Presidium approved the Overview of Court Practice in the Consideration of Competition Protection Cases and Administrative Violation Cases in that area (hereinafter the "Overview"). On the whole, the Overview is a summary and consolidation of the existing practice of the commercial (arbitrazh) courts in competition protection cases and does not contain new provisions. Below we cite some of the conclusions and generalizations reflected in the Overview.
The RF Supreme Court stated that the antimonopoly inspection report compiled by the antimonopoly authority does not establish any rights or obligations and, specifically for this reason, cannot be appealed in a court. The document actually only performs a descriptive function and does not contain binding requirements.
The court acknowledged that an antimonopoly authority director's order to conduct an inspection may be challenged in court. This conclusion allows companies to not wait until the regulator adopts other acts establishing rights and obligations (for example, a warning or a decision in the case) in order to challenge the position of FAS in court.
The court also stated that an antimonopoly authority warning to cease actions (omissions) which show evidence of antimonopoly law violation may be challenged in court. FAS warnings generally contain requests strictly regulating the activity of business entities, and complying with them often leads to changing business practices which, in turn, may affect the overall efficiency of the undertaking's activity. Thus, antimonopoly authority warnings impose certain obligations on business entities and affect their rights in entrepreneurial activity. These are criteria of nonregulatory legal acts, which may be appealed in court in accordance with Article 198 of the RF Commercial (Arbitrazh) Procedure Code.14
The Overview also states that the fact of whether an anticompetitive agreement has been reached does not depend on it being concluded in the form of a contract according to the rules of civil law. Prohibited terms of an anticompetitive agreement may be in any form and content and may be proved, inter alia, based on the business entity's actual behavior.
The FAS' request to provide the requisite information, documents and explanations in an initiated antimonopoly case is deemed to be well argued if it states the procedural reason for requesting the information, the legal basis for the request for information and the provision of the Competition Law which, in the regulator's opinion, the business entity could be violating. The request should not reveal the specific questions the antimonopoly authority has, or the objective and circumstances of the audits being conducted.
Amendments softer on small business
Starting July 4, 2016 the amendments introduced by Federal Law No. 264-FZ15 to the Competition Law softening the effect of antimonopoly legislation on small business went into effect. Now unscheduled field audits of such entities conducted on the basis of communications from individuals or legal entities or the mass media, and based on evidence of violation discovered by FAS may be conducted only following approval by the appropriate prosecutor's office.
The Law also set a limit of RUB 400 million for business entities to be declared dominant. For instance, when certain conditions are met, a legal entity or individual entrepreneur cannot be declared dominant if their revenue from the sale of goods for the last calendar year does not exceed RUB 400 million. Accordingly, the prohibitions on abuse of dominance in Article 10 of the Competition Law do not apply to that entity. Furthermore, the changes set up exceptions for some types of "other" anticompetitive agreements if their parties' revenue does not total more than RUB 400 million.
Finally, the changes altered the criteria for applying the requirement for mandatory merger control approval by raising the threshold of the business entity's and its group's total asset value for seeking FAS clearance of transactions involving shares/participatory interests, assets and rights to such company from RUB 250 to 400 million.
***
It can be said that, on the whole, although with some reservations, 2016 did not yield any "revolutionary" changes of antimonopoly regulation in Russia, and the year can be described as a period devoted to stabilizing and unifying the practice of applying the law. However, it looks like the relative stability of antimonopoly lawmaking will not last long and the "fifth antimonopoly package" will come close on the heels of the "fourth"16...
Footnotes
1. Federal Law No. 275-FZ on Amendments to the Federal Law on the Protection of Competition and Certain Legislative Acts of the Russian Federation of October 5, 2015.
2. Federal Law No. 273-FZ on Amendments to the Federal Law on the Fundamentals of State Regulation of Trade in the Russian Federation and the Russian Federation Administrative Offenses Code of July 3, 2016.
3. Federal Law No. 381-FZ on the Fundamentals of State Regulation of Trade in the Russian Federation of December 28, 2009.
4. FAS Russia's clarifications on certain issues of applying Federal Law No. 381-FZ of December 28, 2009 on the Fundamentals of State Regulation of Trade in the Russian Federation in the version of Federal Law No. 273-FZ of July 3, 2016, No. AK/60976/16 of September 5, 2016, http://fas.gov.ru/upload/documents/разъяснения%20по%20Закону%20о%20торговле.PDF; FAS Russia's clarifications on certain issues of applying Federal Law No. 381-FZ of December 28, 2009 on the Fundamentals of State Regulation of Trade in the Russian Federation in the version of Federal Law No. 273-FZ of July 3, 2016 published on November 18, 2016 at http://fas.gov.ru/upload/documents/О%20разъяснении%20применения%20Закона%20о%20торговле.pdf.
5. The US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act have extraterritorial effect.
6. RF Supreme Court Ruling No. 305-KG15-7123 of November 9, 2015, in case No. А40-42997/2014.
7. Clarification No. 4 "The Agreement on Innovation and High-Tech" and Clarification No. 7 "Procedure for Applying the Competition Law Taking into Account the Rules for Utility Connection, the Rules for Non-Discriminatory Access, the Rules for Connecting and the Legislation on Heating Supply" will not be considered.
8. Approved by FAS Russia Presidium Minutes No. 2 of February 10, 2016. Published on the website http://fas.gov.ru/documents/documentdetails.html?id=14264.
9. Approved by FAS Russia Presidium Minutes No. 3 of February 17, 2016. Published on the website http://fas.gov.ru/documents/documentdetails.html?id=14265.
10. Approved by FAS Russia Presidium Minutes No. 3 of February 17, 2016. Published on the website http://fas.gov.ru/documents/documentdetails.html?id=14266.
11. Approved by FAS Russia Presidium Minutes No. 4 of February 24, 2016. Published on the website http://fas.gov.ru/documents/documentdetails.html?id=14268.
12. Approved by FAS Russia Presidium Minutes No. 7 of May 25, 2016. Published on the website http://fas.gov.ru/documents/documentdetails.html?id=14664.
13. RF Supreme Court Ruling No. 25 on the Application by the Courts of Certain Provisions of Section I of Part One of the Russian Federation Civil Code of June 23, 2015.
14. Russian Federation Commercial Procedure Code No. 95-FZ of July 24, 2002.
15. Federal Law No. 264-FZ on Amendments to the Federal Competition Law and Certain Legislative Acts of the Russian Federation of July 3, 2016.
16. See, for example, A.G. Tsyganov's speech at the Russian Corporate Counsel Association (RCCA) roundtable in October 2016: http://fas.gov.ru/press-center/news/detail.html?id=47378.
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