Competition law in the Netherlands 2019 - An annual overview by Loyens & Loeff N.V - Loyens & Loeff
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EU COMPETITION TEAM Competition law in the Netherlands 2019 An annual overview by Loyens & Loeff N.V. 40299577
1. Merger control 2. Cartels 3. Abuse of dominance 4. Trends & preview 2020 5. Your trusted advisors CONTENT
The Loyens & Loeff EU Competition Team in 2019 We are pleased to present to you this overview of competition law developments in the Netherlands in 2019. With Martijn Snoep, eminent competition lawyer, in office as chairman of the Dutch Authority for Consumers & Markets (the ACM) for over a year now, it would appear that the ACM has embarked on a more interventionist policy course. Multiple dawn raids were carried out, no fewer than five merger control cases were referred to the second phase for an in-depth investigation and the ACM published several noteworthy reports and policy guidelines. Especially the healthcare sector, digital markets and the food sector - areas in which our team has a strong focus and track record – have been at the centre of the ACM’s attention. This resulted in another busy year for Loyens & Loeff’s EU Competition Team. We were involved in several concentrations, court proceedings and cartel and abuse of dominance investigations. For example: • We represented clients in two Phase II merger cases, one of which is still pending. We successfully advised textile services provider CleanLease and its majority shareholder AAC on the acquisition of its competitor Lips, uniting numbers 1 and 2 in the market. • In the digital sector, we advised and represented various online platforms and retailers, big tech companies and data driven companies. • 2019 also marked the year in which we published the first comparative handbook in relation to EU digital competition law. We also launched our own Digital Competition Course. In 2020 we will continue to follow developments in these and other sectors in order to assist our clients on competition law matters in an increasingly complex digital landscape. Please do not hesitate to contact us should you have any questions. We will be happy to discuss. Loyens & Loeff - Amsterdam, December 2020 3
The Loyens & Loeff EU Competition Team in 2019 - Digital Competition Book launch at the annual IBA Conference in Seoul In 2019, we published the first comparative handbook in relation to EU digital competition (“Digital Competition Law in Europe: A Concise Guide”). This book provides a concise and comprehensive coverage of enforcement practices and policies in the field of digital competition law of six European competition authorities. The book was launched at the annual IBA Conference in Seoul. Digital Competition Course In collaboration with Oxera Economics and Leiden University, we organised a Digital Competition Course focusing on pricing, market power and the role of data in digital markets, combined with a network event. This course was attended by clients and prospects and was appreciated very highly by the various participants. Competition & Cocktails client event In September 2019, we organised our annual Competition & Cocktails client event, this year themed “The Future of Competition”. In addition to presentations of our digital competition experts, Dr T. Schrepel of Harvard and Utrecht Universities gave his view on how competition law applies to blockchain. Please contact us should you wish to attend our event in 2020. Loyens & Loeff - Amsterdam, December 2020 4
A. Merger Control – Facts & Figures Numbers: Up to 8 December 2019, the ACM has taken the following decisions in merger 116 cases: 114 1st phase decisions 112 Short decisions 105 113 Full decisions 6 110 Permit required 5 111 Exemptions from standstill obligation 3 108 Remedies required 0 106 2nd phase clearance decisions (1 with remedies) 2 104 105 Referral to the European Commission 0 102 Cleared Phase 1 Short form Prohibition decisions 1 (eventually permitted concentrations through ministerial approval) Highlights: Page 6: For the first time in history, the Dutch government – instead of the ACM – cleared a concentration in the “third phase” (PostNL/Sandd). Page 7: The ACM cleared two concentrations in Phase II. Page 8: The ACM allowed three derogations from the standstill obligation that normally applies during its merger control review. Page 8: The Dutch Healthcare Authority (the NZa) – which assesses certain healthcare concentrations – revoked a clearance decision as the parties misinformed the authority and healthcare insurers. Beware! The ACM increasingly requests strategic internal documents to understand the rationale behind a concentration and its possible anti-competitive effects. Loyens & Loeff - Amsterdam, December 2020 6
B. Merger Control – Noteworthy cases Dutch government approves PostNL/Sandd in “third phase” • In brief: Following a Phase II investigation, the ACM prohibited the acquisition of Sandd by PostNL, which would create a near-monopolist in the Dutch postal market. Following this prohibition decision, for the first time in history the Dutch government cleared the concentration in the ministerial review procedure (phase III). • The transaction: The transaction concerned the acquisition of Sandd by PostNL. PostNL is the largest postal operator in the Netherlands. Sandd is, in practice, PostNL’s largest and only sizeable competitor in the Dutch market. • Phase I: The ACM had concerns about the position of the merged entity on the market for business mail. PostNL would be a near-monopolist after the acquisition as PostNL and Sandd are the only two national operators on this market. This could allow the merged entity to increase its prices on this market and/or reduce the quality of its services. Hence, the ACM decided that a Phase II investigation was required. • Phase II: The ACM decided not to grant a permit to allow the concentration, as its projections indicated that, without Sandd exercising competitive pressure, PostNL could increase its prices for business mail by 30 to 40 per cent after the acquisition. In addition, the ACM expected that the acquisition would lead to higher prices for consumer mail. Since the parties maintained that the acquisition was necessary for maintaining a postal service that is efficient and viable, the ACM also considered that any such benefits of the acquisition could not offset the negative consequences of the elimination of competition between PostNL and Sandd. • Phase III: in September 2019, The Dutch Deputy Minister of Economic Affairs and Climate Policy nevertheless granted – for the first time in history – a permit for the concentration on the basis of reasons of general public interest. This procedure was based on Article 47 of the Dutch Competition Act. The Deputy Minister attached a number of conditions to the clearance. For example, the merged entity's pricing should be based on actual costs. Loyens & Loeff - Amsterdam, December 2020 7
B. Merger Control – Noteworthy cases Phase II clearance: Sanoma / Iddink Phase II clearance: Active Capital / LipsPlus In short: Sanoma had notified its intention to acquire sole control of Iddink. In short: Active Capital Company B.V. (ACC), a PE investor that had already Sanoma publishes educational materials, while Iddink distributes these. One acquired CleanLease, the largest laundry service for linen and workwear for of Iddink’s most successful products is Magister, one of the most-used Dutch Dutch hospitals, wished to acquire LipsPlus, a laundry services company that learning management systems (LMS) which provides access to digital focuses on the supply and maintenance of flat linen in the healthcare sector. educational content. Loyens & Loeff represented ACC and CleanLease in the merger proceedings. Phase I: The ACM’s investigation revealed that more than half of all secondary schools in the Netherlands use Magister. The ACM assessed Phase I: The ACM decided on 4 June 2019 that a permit was required for whether post-closing would have resulted in other providers of digital clearance due to the fact that the ACM could not rule out possible competition educational having fewer opportunities to offer their educational materials to concerns on the basis of a narrow product market for the delivery of laundry students. services to hospitals only. Phase II: The ACM eventually cleared the transaction subject to conditions. Phase II: In Phase II, the parties put forward various arguments, including These conditions must ensure that a level playing field between publishers a comprehensive bidding analysis indicating that there remained sufficient (i.e. Sanoma vis-à-vis its competitors) continues to exist. In particular, competition as well as proof of strong countervailing buying power, Sanoma’s competitors must (a) be granted equal access to Magister as convincing the ACM to clear the transaction on 29 August 2019 without Sanoma and (b) receive the same Magister data (which publishers may need imposing any conditions. in order to improve their services) as Sanoma. Loyens & Loeff - Amsterdam, December 2020 8
B. Merger Control – Noteworthy cases ACM allowed three exemptions from the standstill obligation • In brief: The parties to a concentration are prohibited from implementing all or part of the notified transaction until the ACM’s clearance has been obtained. A violation of this requirement may result in high fines and it appears that competition authorities increasingly pay attention to violations of this standstill obligation (often referred to as ‘gun-jumping’). However, at the request of the notifying party, the ACM may, on important grounds, grant an exemption from this obligation. Although such exemptions are rare, the ACM granted no fewer than three of such exemptions in 2019. • St. Jansdal / IJsselmeerziekenhuis Lelystad • Mirage Toys Group B.V. / Green Swan Logistics B.V. (Intertoys) • Sensire / Trimenzo Loyens & Loeff represented Sensire in this matter. The NZa revoked a clearance decision as the parties had misinformed the authority and healthcare insurers • Healthcare specific merger control regime: Concentrations in the healthcare sector also require the prior approval of the NZa under the so-called “healthcare specific concentration assessment”. Under this regime, the NZa assesses, inter alia, the financial impact of the concentration on the provision of healthcare and considers whether internal and external stakeholders have been properly informed and involved in the merger process. • Clearance revoked in Erasmus MC / IJsselland: Following an appeal by a healthcare insurer, the NZa revoked a clearance decision as the parties stated to the NZa that healthcare insurers had been properly informed. This was not the case, since healthcare insurers were told that the parties only wished to cooperate while in fact the transaction amounted to an acquisition of control over IJsselland by Erasmus MC. Loyens & Loeff - Amsterdam, December 2020 9
2. Cartels A. Main Developments B. Court Appeals Regarding ACM Decisions C. Follow-on Damages Claims
A. Main Developments - Cartels and Antitrust (1) Facts 2019 Pending Cartel Investigations (publicly known) • No publicly known fining decisions for substantive infringements of the cartel Civil engineering prohibition (situation 31 December 2019) In May 2019, the ACM launched an investigation into irregularities in tender • One fine for a failure to cooperate (see page 10) proceedings in the civil engineering sector in the municipality of Amsterdam. The ACM • One investigation continued which started at the end of 2018 announced that it had received tip-offs suggesting that, in a number of tenders that the • Two new investigations announced municipality had organised, illegal agreements had been made between several building contractors about prices, and about who should be awarded the contracts. • Four enforcement requests to the ACM were made public, all of which have The tenders were organised for projects ranging between EUR 100,000 and 2 million. been denied The ACM conducted dawn raids at several companies. The ACM is still in the process • ACM published several Guidelines concerning cooperation between of assessing whether the cartel prohibition has indeed been infringed (situation businesses and price-fixing among independent contractors 31 December 2019). Enforcement Decisions Price-fixing between consumer goods manufacturers and retailers ACM Decision 20 June 2019, Ryanair On 27 December 2018, the ACM announced an investigation into price-fixing • Ryanair submitted an enforcement request to the ACM against KLM and agreements between consumer goods manufacturers and retailers (including online Schiphol, as it contended that these companies infringed the Competition retailers). The ACM suspected that some consumer goods manufacturers are trying to Act. According to Ryanair, KLM and Schiphol would have made agreements conclude minimum resale price agreements with retailers for their products. As part of about flight capacity and its distribution at Schiphol airport. These this investigation, the ACM conducted dawn raids at various firms. No enforcement agreements allegedly were aimed at protecting KLM's leading position. decision has yet been taken (situation 31 December 2019). • The ACM carried out an initial investigation into the alleged violations. This initial investigation did not reveal any indications of anti-competitive Dawn raids in the agricultural sector behavior on the part of KLM and Schiphol. The ACM therefore rejected the On 18 November 2018, the ACM announced that it had conducted dawn raids at enforcement request. several large traders in the agricultural sector. The ACM suspects that they have • Contrary to what Ryanair suggests, there were no indications that the made illegal arrangements about the purchase price that they pay to farmers. applicable ceiling of 500,000 flight movements would have been bilaterally The ACM suspects that the traders have coordinated the purchase prices amongst coordinated between KLM and Schiphol. Nor were there any indications that themselves. The ACM believes that this type of behaviour may result in farmers being this ceiling would have been established on the initiative of these two harmed because they are being paid a lower price for their products. The ACM companies. expects to present the results of its investigation ‘in the coming months’ (situation 31 December 2019). Loyens & Loeff - Amsterdam, December 2020 11
A. Main Developments - Cartels and Antitrust (2) New Guidelines The ACM imposes a fine of EUR 1.84 million for deleting Guidelines regarding price-fixing among independent contractors WhatsApp conversations during a dawn raid • Independent contractors are allowed to make collective arrangements about rates in order to earn a minimum income. This has been laid down in the ‘Guidelines regarding price-fixing among independent contractors’. • On 11 December 2019, the ACM announced that it had imposed a fine on a Independent contractors who work side by side with one or more employees company for obstructing an investigation. During a dawn raid, employees of the and who, in day-to-day operations, are indistinguishable from those employees company under investigation left several WhatsApp groups and deleted chat are not considered ‘undertakings’ within the meaning of the Dutch Competition conversations on WhatsApp. The ACM believes that these chats could have Act. In such cases, the cartel prohibition does not apply to that independent contained evidence relating to the investigation. contractor. • According to the ACM, the company in question had acknowledged that some of its employees had indeed wrongfully left several WhatsApp groups and Guidelines regarding cooperation between businesses deleted chat conversations. The company has fully cooperated with the • In February 2019, the ACM published Guidelines for cooperation between investigation into the deleted materials to an extent that goes beyond what is competitors and for arrangements between suppliers and buyers. In these prescribed by law. That is why ACM has reduced the fine by 20 per cent, Guidelines, the ACM explains how the Dutch Competition Act applies to leaving a fine of EUR 1.84 million. various types of common arrangements between competitors and between suppliers and buyers. These Guidelines are aimed primarily at undertakings, trade organisations, and their advisors. The guideline on arrangements between suppliers and buyers illustrates the ACM’s increased interest in the effects of vertical agreements. Investigation into big tech and payments On 22 October 2019, the ACM announced that at the request of the Dutch Minister of Finance, it had initiated a market study into the activities of major tech firms (referred to as Big Techs by the ACM) on the Dutch payments market. As examples of Big Techs, the ACM explicitly mentions Apple, Google, Amazon, and Facebook (also commonly referred to as ‘GAFA’). In its market study, the ACM intends also to examine whether Chinese Big Techs (such as Tencent and Alibaba) may enter the Dutch payments market. The ACM aims to announce the initial results of the study by mid-2020. Loyens & Loeff - Amsterdam, December 2020 12
B. Court cases Trade and Industry Appeals Court (CBb) Flour cartel • In 2010, the ACM imposed fines on 14 flour producers for entering into prohibited cartel agreements. On 26 January 2017, the Rotterdam District Court ruled that the ACM had rightly fined one of the investment companies for the infringement perpetrated by its former portfolio company. The private equity investment firm appealed against this decision to the CBb. • In May 2019, the CBb confirmed the Court's ruling: the ACM had rightly imposed a fine on the investment firm for participation in the flour cartel by the company in which it held a controlling interest. The CBb concluded that the investment firm exercised decisive influence over the company that participated in the flour cartel during a part of the infringement period. The CBb ruled that during that period, the investment firm and the subsidiary company could be regarded as a single economic entity within the meaning of competition law. The infringement of the subsidiary company could therefore be attributed to the investment firm. Compensation of damages after revocation of fining decisions • In September 2019, the CBb decided that the ACM must pay damages of EUR 40,000 each to three real estate auction traders. • The ACM had previously imposed high fines on traders for allegedly being involved in an infringement of the cartel prohibition in trade on foreclosure auctions of homes. The CBb had already ruled in July 2017 that the ACM had not provided sufficient evidence for this infringement and therefore annulled the fines. • The traders requested the CBb to compensate them for the damages they had suffered. The CBb ruled that most of the alleged damages did not qualify for compensation. However, the dealers were entitled to compensation for reputational damage because of the media coverage of the case and the long duration of the proceedings. Loyens & Loeff - Amsterdam, December 2020 13
C. Follow-on Damages Claims - District Court of Amsterdam Air cargo Truck cartel St. Cartel Compensation (SCC) / KLM ea. Equilib Netherlands BV / KLM ea. St. Trucks Cartel Compensation ea. / Daf Trucks ea. • This judgment related to the Air Cargo case (COMP/39.258) • This judgment related to the Trucks case (COMP/39824) • May 2019: the Court ruled in two judgments that Dutch law applies to all • May 2019: the Court ruled that the claimants had insufficiently substantiated follow-on damages claims resulting from the international air cargo cartel. their claims. The claimants were given until 18 September 2019 to provide The Court had to decide which legal system (or systems) would govern the sufficient evidence regarding transactions that were allegedly affected by the civil-law damages claims of the indirect purchasers. cartel. • Since the anti-competitive conduct had occurred before the Rome II Regulation • The Court emphasised that the bundling of claims does not remove their entered into force in January 2009, this question had to be adjudicated under individual character. the Dutch private international law rule which provides that claims arising from • The Court consequently held that claimants should have provided sufficient an infringement of competition law are "governed by the law of the state where facts to determine whether or not a purchaser, lessee and/or user was affected the competitive act affected the competitive relationships". by the cartel to allow the Court to determine whether or not the possibility of • Thus, the principal question with regard to every individual claimant's claim was harm is plausible. The Court noted that – in the absence of this information – in which state the air freight cartel had allegedly produced anti-competitive the defendants could simply contest the allegations made by the claimants. effects. Due to the worldwide impact of the air cargo cartel, it would be difficult That would make the proceedings ineffective, since the Court would then have and impracticable to precisely identify the affected markets. Therefore, no choice but to reject the claims. the Court decided to adopt a more practical approach. In doing so, it ruled • The Court did not decide whether the European Commission’s statement of that since the cartel had a worldwide impact, including in the Netherlands, objections would have to be disclosed, as demanded by one of the claimants. Dutch law could be, and in fact had to be, applied to all individual claims. The Court indicated that it will decide on this question later, as part of the The court justified this approach with reference to the principles of due proceedings on the merits of the claims. The Court also decided to formally join process ("goede procesorde") and the European law principle of effectiveness. all pending Dutch trucks cartel follow-on proceedings (currently more than ten) before the Amsterdam District Court. Loyens & Loeff - Amsterdam, December 2020 14
3. Abuse of dominance
Notable cases Apple App Store Dutch Railways Fine ACP accepts commitmenst offered by OMS In April 2019, the ACM announced that it had On 27 June 2019, the District Court of Rotterdam On 2 December 2019, the ACM announced that it launched an investigation into the question ruled in the case concerning the fine imposed by the had accepted commitments offered by OMS – the whether Apple abuses its dominant position ACM on the Dutch Railways (Nederlandse largest provider of radio advertising space – in through its App Store. The ACM started the Spoorwegen; ‘NS’) and annulled the fine of over EUR order to close an investigation into an alleged investigation following signals it had received from 40 million that the ACM had imposed on NS. abuse of a dominant position by OMS. other app providers during its earlier general In 2017, the ACM ruled that NS had abused its In its commitment decision, the ACM does not market study into app stores. dominant economic position as a monopolist on the conclude whether or not there actually has been The aforementioned market study revealed that main rail network in the Netherlands in the tender an abuse of dominance. The decision notes, app providers depend on app stores in order to process for a regional public transport contract in the however, that OMS is the largest provider of radio reach users. For numerous apps, no realistic province of Limburg, by submitting a bid below cost advertising space and that OMS had a rebate alternatives to Apple’s App Store and Google’s and withholding information from rivals on railway scheme in place, in which the discount granted to Play Store exist. That provides, at least in theory, station infrastructures. This information was of a customer was dependent upon the percentage Apple and Google with the opportunity of setting importance for the tender. For this conduct, the ACM of its overall advertising budget that was spent unfair conditions. The conflicting interests of had imposed a fine of 40,950,000 euro on NS in with OMS. The higher the share of the overall Apple and Google, as they are also app providers 2017. budget that was spent with OMS, the higher the themselves, may pose antitrust problems. NS appealed against this decision. The Rotterdam discount. According to other app providers, they do not District Court subsequently annulled the fine. The As a result, customers would be tempted to spend always have a fair chance against Apple’s own Court established that the ACM had not proved that an even larger part of their budget with OMS, apps or against apps that Google has pre- NS has a dominant position on the main rail network, entailing the risk that other radio stations not installed on phones. In addition, providers of since it had not investigated the conditions and represented by OMS would not receive enough digital products and services are required to use obligations attached to NS’ concession for operating advertising revenues in order to remain active. In Apple’s and Google’s payment systems for in-app the main rail network. Therefore, the Court did not the decision, the ACM accepted a commitment by purchases, and they are also required to pay 30% investigate whether NS had abused that allegedly OMS that it would no longer use such rebate commission in the first year. dominant position in the tender process for the schemes. Furthermore, they are not always able to use all regional public transport contract. The ACM has the functionalities of an iPhone. announced that it has filed an appeal against the Court’s judgment. Loyens & Loeff - Amsterdam, December 2020 16
4. Trends & preview 2020
Trends in Dutch competition law The ACM rolls out its digital agenda • In the previous edition of this booklet, we highlighted the ACM’s particular interest in the digital sector. • Whereas throughout 2018 the ACM’s interest was mostly shown through market studies, in 2019 the ACM demonstrated it is now ready to enforce. The investigation into Apple’s App Store and the dawn raids in the retail sector (see sections on abuse of dominance and cartels, respectively) are witness of the ACM’s readiness to enforce. • The ACM also calls for new enforcement tools in order to be able to act promptly and effectively vis-à-vis digital platforms and other ‘big techs’, even before they engage in anti-competitive behaviour (in particular the abuse of a dominant position). The ACM has emphasised its view that such instruments are necessary in a report dated 6 August 2019, and again in a joint publication with the competition authorities of Belgium and Luxembourg dated 2 October 2019. New ACM chairman gets up to speed The new chairman of the ACM, Martijn Snoep took office on 1 September 2018 • With Mr Snoep having now been in office for more than a year, it has become clear that the ACM has become more interventionist under his presidency. • New cartel and dominance investigations have been initiated (see relevant sections). • No fewer than five merger cases were referred to phase II in 2019. • Vertical agreements are back on the ACM’s enforcement agenda (evidenced by both the aforementioned dawn raids and the new policy rules). Martijn Snoep Loyens & Loeff - Amsterdam, December 2020 18
What 2020 may bring… • Closer scrutiny in merger cases is likely to continue • Tech will remain one of the spearheads of the ACM’s enforcement agenda, with the investigation into Apple’s App Store being a potential landmark case to look out for in 2020 • Vertical agreements will be more prominently on the ACM’s agenda • The ACM is expected to publish its enforcement agenda for 2020 and 2021; the digital economy and the energy transition have already been announced as key priorities on this agenda • It seems highly likely that the ACM will again impose potentially high fines for substantive infringements in 2020 for the first time since 2017 • …and Loyens & Loeff looks forward to a continued fruitful cooperation with you! Loyens & Loeff - Amsterdam, December 2020 19
5. Your trusted advisors
Your trusted advisors - Contact Gert-Wim van de Meent Marc Wiggers Marc Custers Attorney at law Attorney at law Attorney at law Partner Partner Counsel T +31 20 578 59 66 T +31 20 578 56 14 T +31 20 578 55 22 M +31 6 51 56 27 61 M +31 6 51 10 27 75 M +31 6 20 60 46 05 E gw.vdmeent@loyensloeff.com E marc.wiggerst@loyensloeff.com E marc.custers@loyensloeff.com Loyens & Loeff - Amsterdam, December 2020 21
Your trusted advisors - CV’s Gert-Wim van de Meent Marc Wiggers Attorney at law Attorney at law Partner Partner Gert-Wim van de Meent specialises in EU law, competition law (merger control, Marc gives advice on the application of competition rules (cartel prohibition, antitrust and state aid), procurement law and healthcare law. His main focus is ban on abuse of dominance, prohibition on state aid and merger control) and on regulated sectors such as food, healthcare & life sciences. He is currently has broad experience litigating in this area, for instance in cartel and damages heading the integrate legal/tax Food & Beverages team. Gert-Wim was a proceedings. member of Loyens & Loeff’s Executive Board between 2016 and 2018. He is a member of the Loyens & Loeff Competition Litigation Team and the Gert-Wim is professor of European and national procurement law at the Corporate Investigations Team. He focuses on regulated sectors such as tech, University of Amsterdam and regularly publishes in academic literature. life sciences, pharma and the financial sector. Marc is senior lecturer at the Grotius Academy where he teaches postgraduate courses in healthcare and competition law. He also teaches at universities on a regular basis. He gives lectures and publishes frequently in professional journals on issues relating to competition, tech and healthcare law. T: +31 20 578 59 66 T: +31 20 578 56 14 M: +31 651 56 27 61 M: +31 6 5110 2775 E: gw.vdmeent@loyensloeff.com E: marc.wiggers@loyensloeff.com Loyens & Loeff - Amsterdam, December 2020 22
Your trusted advisors - Contact Marc Custers Attorney at law Counsel Marc specialises in EU law and competition law (merger control, anti-trust and state aid). He has broad experience in proceedings before the European and Dutch courts, the European Commission and the Dutch Competition Authority. He has also assisted clients in complex cartel damages proceedings and has been involved in various important state aid matters. Marc is editor of the Tijdschrift voor Staatssteun (a State aid journal). Marc is a member of the Loyens & Loeff Competition Litigation Team. He also is a member of the Netherlands Association for European Law and the Netherlands Association for Competition Law. He has published various articles on competition law and is a regular speaker at conferences. T: +31 20 578 55 22 M: +31 620 60 46 05 E: marc.custers@loyensloeff.com Loyens & Loeff - Amsterdam, December 2020 23
EU Competition Team We wish you all the best for 2020 Loyens & Loeff - Amsterdam, December 2020 24
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