When the competition authorities come to call, even the most robust compliance programmes can be put to the test. Understanding the authorities' powers, mistakes that can be made, how to deal with conflict between staff and directors, legal privilege and communications strategy can make all the difference.
The Dawn Raid Action team is Wragge & Co's own specialist unit, part of the Antitrust team. Led by partner Bernardine Adkins, its combination of antitrust and litigation experts offer clients immediate support in the event of an Office of Fair Trading or European Commission dawn raid.
And before the competition authorities strike, it offers comprehensive training to ensure clients are prepared for the realities of a dawn raid. Using a bespoke scenario, a team of investigators will put a company through its paces in a mock dawn raid on selection sites or site. The effectiveness of existing compliance procedures, level of understanding and attitudes among management and staff will be placed under the microscope.
As well as providing officials, the team will supply a defence team member to advise staff on officials' powers and procedural or substantive competition law issues that arise. An expert from the firm's IT department can also be on standby to oversee and report on officials' access to electronic data.
Once the mock dawn raid team has departed, Wragge & Co will provide immediate feedback to personnel. Clients can expect a full report, identifying where procedures failed or where they were inadequate, as well as areas of bad practice. A full set of practical recommendations will then be issued, to help companies address the fault lines in their dawn raid handling.
To arm clients with practical steps to take in the event of an unannounced dawn raid, or on improving policies and procedures, Wragge & Co's Antitrust team regularly hosts workshops and issues useful tips for action to take using the alert, analysis and action service.
For more information, contact Bernardine Adkins (bernardine_adkins@wragge.com).
