Culture of Compliance - Meaning and Proof

Bill Keane

Australian Journal of Competition and Consumer Law

Bill Keane, ‘Culture of Compliance - Meaning and Proof’ (2019) 27(3) AJCCL 204

“The existence of a "culture of compliance" is regularly the subject of submissions and evidence in pecuniary penalty hearings. However, it is not always clear what "culture of compliance" is or what evidence is most relevant to its existence. This report surveys some of the more informative penalty decisions on this penalty factor to provide practitioners with practical assistance.“

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Evidentiary issues in cartel conduct cases