This paper undertakes a qualitative analysis of the relationship between EU cartel enforcement in the chemical industry in the period 1997-2010 and compliance measures announced in the Annual Reports of the undertakings involved. It goes on to focus on Akzo Nobel NV’s unique use of an internal amnesty programme, and the level of compliance in the industry following this period of enforcement. Its findings are consistent with cartel enforcement prompting significant investment in compliance measures, with some evidence of those measures resulting in the earlier reporting of cartels in return for leniency and in enforcement action against only one hard core cartel in the decade that followed.

The article was recently cited by EVP M. Vestager in her speech available here with the following quote: “And a recent study of cartel enforcement in the chemical industry – an industry that saw a lot of enforcement activity, in the first decade of this century – gives an interesting case study of what that really means. In the short term, enforcement elsewhere in the industry drove companies to look for skeletons in their own closets, and rush for immunity before others got there. Then, in the longer term, those companies made big investments in compliance programmes, to try to stop these things ever happening again."