Scenario: What are the leniency conditions? — the opening question on “Investigated for Price-Fixing with Rivals: Applying for Leniency”, with a reference situation of around 132,500 USD, under the law on 20 October 2026.
1. The current legal basis for EXP-6060
The directly governing framework is Competition Law 23/2018/QH14 on the leniency policy (Article 112) and Decree 75/2019/ND-CP setting exemption and reduction levels for undertakings that voluntarily report a restrictive agreement.
Leniency rewards only those who come first: the first undertaking to report voluntarily and supply valuable evidence can be fully exempted from the fine, later applicants receive reductions in filing order; the standing conditions are ending the conduct, cooperating fully, and not having coerced partners into the price-fixing agreement.
2. Applying the rules to the concrete situation
How much to disclose is a strategic question: the leniency filing must describe the agreement, the parties, the period and enough evidence for the authority to open an investigation, but it should be filed through counsel, marked confidential, with preparation for the risk that the material surfaces in follow-on damages claims by harmed customers.
The client’s questions on this topic — What are the leniency conditions?; Does the first applicant get full immunity?; Where is the application filed?; How much must we disclose? — form a single decision chain: a wrong answer at the first link distorts every later link, so this article keeps the chain’s order and always returns to the file, the leniency application filed with the National Competition Commission before an investigation decision issues, the internal evidence map, and minutes ending all price contacts with rivals, to prove its conclusions.
3. Working through the questions companies actually ask
What are the leniency conditions?
Leniency rewards only those who come first: the first undertaking to report voluntarily and supply valuable evidence can be fully exempted from the fine, later applicants receive reductions in filing order; the standing conditions are ending the conduct, cooperating fully, and not having coerced partners into the price-fixing agreement. This answer is tied closely to the leniency application filed with the National Competition Commission before an investigation decision issues, the internal evidence map, and minutes ending all price contacts with rivals within Competition Law 23/2018/QH14 on the leniency policy.
Does the first applicant get full immunity?
How much to disclose is a strategic question: the leniency filing must describe the agreement, the parties, the period and enough evidence for the authority to open an investigation, but it should be filed through counsel, marked confidential, with preparation for the risk that the material surfaces in follow-on damages claims by harmed customers. Applied to the file, the leniency application filed with the National Competition Commission before an investigation decision issues, the internal evidence map, and minutes ending all price contacts with rivals shows this conclusion holds against Competition Law 23/2018/QH14 on the leniency policy.
Where is the application filed?
How much to disclose is a strategic question: the leniency filing must describe the agreement, the parties, the period and enough evidence for the authority to open an investigation, but it should be filed through counsel, marked confidential, with preparation for the risk that the material surfaces in follow-on damages claims by harmed customers. The test of this conclusion sits in the leniency application filed with the National Competition Commission before an investigation decision issues, the internal evidence map, and minutes ending all price contacts with rivals and the Competition Law 23/2018/QH14 on the leniency policy framework.
How much must we disclose?
How much to disclose is a strategic question: the leniency filing must describe the agreement, the parties, the period and enough evidence for the authority to open an investigation, but it should be filed through counsel, marked confidential, with preparation for the risk that the material surfaces in follow-on damages claims by harmed customers. To rely on this conclusion, the company needs the leniency application filed with the National Competition Commission before an investigation decision issues, the internal evidence map, and minutes ending all price contacts with rivals matching Competition Law 23/2018/QH14 on the leniency policy.
4. Handling process and the file to prepare
- Measure the situation against Competition Law 23/2018/QH14 on the leniency policy; the internal minute must capture matches and divergences alike.
- Assemble the leniency application filed with the National Competition Commission before an investigation decision issues, the internal evidence map, and minutes ending all price contacts with rivals into one indexed set with a named owner.
- Stick to the order the minutes approved — paperwork first, action second, never the other way round.
- Keep the EXP-6060 file as its own set, ready to produce when an authority or partner asks.
5. A worked figure and the action conclusion
Figures speak: 132,500 USD × 5% = 6,625 USD. A duty at this level requires the file to be complete before the transaction closes.
Conclusion: the point to remember on EXP-6060 is: Leniency rewards only those who come first: the first undertaking to report voluntarily and supply valuable evidence can be fully exempted from the fine, later applicants receive reductions in filing order; the standing conditions are ending the conduct, cooperating fully, and not having coerced partners into the price-fixing agreement.
Frequently asked questions
1. What are the leniency conditions?
Leniency rewards only those who come first: the first undertaking to report voluntarily and supply valuable evidence can be fully exempted from the fine, later applicants receive reductions in filing order; the standing conditions are ending the conduct, cooperating fully, and not having coerced partners into the price-fixing agreement. The accompanying file for this question alone: the leniency application filed with the National Competition Commission before an investigation decision issues, the internal evidence map, and minutes ending all price contacts with rivals.
2. Does the first applicant get full immunity?
How much to disclose is a strategic question: the leniency filing must describe the agreement, the parties, the period and enough evidence for the authority to open an investigation, but it should be filed through counsel, marked confidential, with preparation for the risk that the material surfaces in follow-on damages claims by harmed customers. The accompanying file for this question alone: the leniency application filed with the National Competition Commission before an investigation decision issues, the internal evidence map, and minutes ending all price contacts with rivals.
3. Where is the application filed?
Leniency rewards only those who come first: the first undertaking to report voluntarily and supply valuable evidence can be fully exempted from the fine, later applicants receive reductions in filing order; the standing conditions are ending the conduct, cooperating fully, and not having coerced partners into the price-fixing agreement. The accompanying file for this question alone: the leniency application filed with the National Competition Commission before an investigation decision issues, the internal evidence map, and minutes ending all price contacts with rivals.
4. How much must we disclose?
How much to disclose is a strategic question: the leniency filing must describe the agreement, the parties, the period and enough evidence for the authority to open an investigation, but it should be filed through counsel, marked confidential, with preparation for the risk that the material surfaces in follow-on damages claims by harmed customers. The accompanying file for this question alone: the leniency application filed with the National Competition Commission before an investigation decision issues, the internal evidence map, and minutes ending all price contacts with rivals.
This article has been quality-reviewed by the FLAW AI Legal Council