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Singapore’s Competition Law Landscape: A Comprehensive Guide for Business Success

Sep 13, 2024 | Post

While every effort has been made to ensure the accuracy of this article, it is not a substitute for legal advice. At the time of writing, the information provided was correct. However, we cannot guarantee that the information will still be accurate at the time of reading, as it may have been subject to legislative changes or new case law. Always consult us for advice tailored to your specific situation.

I. Introduction

Singapore’s competition law framework stands as a cornerstone of the nation’s commitment to fostering a vibrant, innovative, and efficient business environment. As a global financial hub and a key player in the Asian market, Singapore has developed a robust legal structure to ensure fair competition, protect consumers, and promote economic growth. This comprehensive analysis delves into the intricacies of Singapore’s competition law, offering businesses and legal practitioners a thorough understanding of the regulations, principles, and practical considerations essential for operating successfully in this dynamic market.

1. Overview of Singapore’s competition law

Singapore’s competition law is primarily governed by the Competition Act, which was enacted in 2004 and came into full effect in 2006. This legislation embodies Singapore’s pro-enterprise approach, aiming to prohibit anti-competitive practices while promoting market efficiency and innovation. The law is enforced by the Competition and Consumer Commission of Singapore (CCCS), formerly known as the Competition Commission of Singapore, which was established to maintain and enhance healthy competition in the local markets.

2. Importance of competition law in Singapore’s business environment

The significance of competition law in Singapore’s business landscape cannot be overstated. It plays a crucial role in:

– Ensuring a level playing field for businesses of all sizes

– Encouraging innovation and efficiency in the marketplace

– Protecting consumer interests by promoting competitive pricing and quality

– Attracting foreign investment by maintaining a transparent and fair business environment

– Supporting Singapore’s economic growth and competitiveness on the global stage

As businesses navigate the complexities of operating in Singapore, a thorough understanding of the competition law framework is essential for compliance, risk management, and strategic decision-making.

II. Historical Context and Development of Competition Law in Singapore

The evolution of competition law in Singapore reflects the nation’s economic transformation and its commitment to fostering a pro-business environment while safeguarding fair market practices. This section explores the historical context and key milestones in the development of Singapore’s competition law regime.

1. Evolution of competition policy in Singapore

Singapore’s journey towards a comprehensive competition policy began in the 1990s, as the government recognized the need to adapt to the challenges of globalization and maintain the country’s economic competitiveness. Prior to the introduction of a dedicated competition law, various sector-specific regulations addressed competition issues in industries such as telecommunications and energy.

Key milestones in the evolution of Singapore’s competition policy include:

– 1992: The government initiated a review of competition policy as part of its efforts to promote a pro-enterprise environment.

– 2001: The Economic Review Committee recommended the introduction of a generic competition law to foster a more competitive economy.

– 2003: The Ministry of Trade and Industry released a draft Competition Bill for public consultation, marking a significant step towards a comprehensive competition law framework.

2. Enactment of the Competition Act

The Competition Act, passed by Parliament in October 2004, represented a watershed moment in Singapore’s approach to competition regulation. The Act was implemented in three phases:

– January 2005: Establishment of the Competition Commission of Singapore (CCS)

– January 2006: Implementation of provisions relating to anti-competitive agreements and abuse of dominance

– July 2007: Introduction of merger control provisions

The phased implementation allowed businesses and regulators to adapt gradually to the new legal framework, ensuring a smooth transition and effective enforcement.

III. Key Regulatory Bodies and Legal Framework

Understanding the regulatory landscape is crucial for businesses operating in Singapore. This section outlines the primary regulatory bodies and the legal framework governing competition law in the country.

1. Competition and Consumer Commission of Singapore (CCCS)

The CCCS, established under the Competition Act, is the primary authority responsible for enforcing competition law in Singapore. Its key functions include:

– Investigating and enforcing prohibitions against anti-competitive practices

– Reviewing mergers and acquisitions for potential competition concerns

– Advising the government and public authorities on competition matters

– Promoting public awareness of competition issues

The CCCS operates as a statutory board under the Ministry of Trade and Industry, ensuring a balance between governmental oversight and operational independence.

2. Competition Act and its amendments

The Competition Act serves as the cornerstone of Singapore’s competition law framework. Its main provisions prohibit:

– Anti-competitive agreements (Section 34)

– Abuse of dominant market position (Section 47)

– Mergers that substantially lessen competition (Section 54)

Since its enactment, the Act has undergone several amendments to enhance its effectiveness and address emerging challenges in the business landscape. Notable amendments include:

– 2007: Introduction of voluntary merger notification regime

– 2018: Expansion of CCCS’s mandate to include consumer protection functions

3. Other relevant laws and regulations

While the Competition Act is the primary legislation governing competition in Singapore, several other laws and regulations complement and interact with it:

– Consumer Protection (Fair Trading) Act

– Price Control Act

– Sector-specific regulations (e.g., Telecommunications Act, Energy Market Authority of Singapore Act)

These laws work in tandem with the Competition Act to ensure a comprehensive regulatory framework that promotes fair competition and protects consumer interests across various sectors of the economy.

IV. Core Principles of Singapore’s Competition Law

Singapore’s competition law is built upon three fundamental pillars that form the backbone of its regulatory framework. These core principles are designed to promote fair competition, protect consumer interests, and foster a dynamic business environment. This section examines each of these principles in detail.

1. Prohibition of anti-competitive agreements

The first core principle, enshrined in Section 34 of the Competition Act, prohibits agreements between undertakings, decisions by associations of undertakings, or concerted practices that have as their object or effect the prevention, restriction, or distortion of competition within Singapore. This prohibition covers both horizontal agreements (between competitors) and vertical agreements (between entities at different levels of the supply chain).

Key aspects of this prohibition include:

– Price fixing arrangements

– Bid rigging

– Market sharing agreements

– Agreements to limit production or supply

The CCCS applies a rigorous economic analysis to determine whether an agreement has an appreciable adverse effect on competition. Certain agreements may be exempted if they generate net economic benefits or fall under specific block exemptions.

2. Abuse of dominant market position

Section 47 of the Competition Act addresses the second core principle, which prohibits any conduct by one or more undertakings that amounts to the abuse of a dominant position in any market in Singapore. This provision aims to prevent powerful market players from exploiting their position to the detriment of competitors and consumers.

Examples of abusive conduct include:

– Predatory pricing

– Exclusive dealing arrangements

– Refusal to supply

– Tying and bundling practices

To establish an abuse of dominance, the CCCS must first determine whether an undertaking holds a dominant position, typically assessed by market share and other factors such as barriers to entry and countervailing buyer power. The conduct in question must then be shown to constitute an abuse of that dominant position.

3. Merger control

The third pillar of Singapore’s competition law, outlined in Section 54 of the Competition Act, prohibits mergers that have resulted, or may be expected to result, in a substantial lessening of competition within any market in Singapore. This provision applies to both completed and anticipated mergers.

Key features of Singapore’s merger control regime include:

– Voluntary notification system

– Ability for CCCS to investigate non-notified mergers

– Substantive test of “substantial lessening of competition”

– Power to impose remedies or block anti-competitive mergers

The merger control provisions are designed to prevent the creation or strengthening of dominant market positions through corporate consolidations, ensuring that market structures remain competitive and conducive to innovation.

These core principles form the foundation of Singapore’s competition law framework, providing a robust structure for regulating business conduct and maintaining a competitive marketplace. As we delve deeper into each of these areas in subsequent sections, it becomes evident how these principles are applied in practice and their impact on businesses operating in Singapore.

V. Prohibited Practices and Conduct

Building upon the core principles discussed earlier, this section delves into specific practices and conduct that are prohibited under Singapore’s competition law. Understanding these prohibitions is crucial for businesses to ensure compliance and avoid potential legal and financial repercussions.

1. Price fixing and bid rigging

Price fixing and bid rigging are considered among the most serious infringements of competition law in Singapore. These practices involve agreements between competitors to manipulate prices or the competitive bidding process.

Price fixing:

– Direct or indirect agreements to fix purchase or selling prices

– Agreements to maintain minimum resale prices

– Coordination on price-related terms such as discounts or credit terms

Bid rigging:

– Cover bidding (submitting non-competitive bids)

– Bid suppression (agreeing to refrain from bidding)

– Bid rotation (taking turns to win bids)

– Market allocation in bidding processes

The CCCS treats these practices as “by object” infringements, meaning they are presumed to have anti-competitive effects without the need to prove actual harm to competition.

2. Market sharing and output limitations

Market sharing agreements and agreements to limit output are also considered severe violations of competition law. These practices artificially restrict competition by dividing markets or controlling supply.

Market sharing:

– Allocation of customers or territories between competitors

– Agreements not to compete in certain geographic areas or for specific customer groups

Output limitations:

– Agreements to restrict production or supply

– Coordinated reduction of capacity or investment

Such agreements are typically viewed as hardcore restrictions of competition, subject to strict scrutiny and enforcement by the CCCS.

3. Exclusive dealing and tying arrangements

Exclusive dealing and tying arrangements can raise competition concerns, particularly when implemented by dominant firms. These practices may foreclose markets to competitors and limit consumer choice.

Exclusive dealing:

– Agreements requiring a buyer to purchase exclusively from a particular supplier

– Long-term contracts that effectively prevent buyers from switching suppliers

Tying and bundling:

– Conditioning the sale of one product on the purchase of another distinct product

– Offering products only as part of a bundle, preventing separate purchases

While not inherently illegal, these practices are assessed based on their effects on competition. Factors considered include the market power of the implementing firm, the duration of the arrangements, and potential efficiency justifications.

4. Predatory pricing and other abusive practices

Predatory pricing and other abusive practices are primarily concerns in the context of abuse of dominance. These practices involve a dominant firm leveraging its market power to exclude competitors or exploit customers.

Predatory pricing:

– Pricing below cost with the intention of eliminating competitors

– Requires evidence of below-cost pricing and a realistic prospect of recouping losses

Other abusive practices:

– Margin squeeze (setting wholesale prices that prevent downstream competitors from competing profitably)

– Refusal to supply essential inputs or access to essential facilities

– Loyalty rebates that have exclusionary effects

The CCCS assesses these practices using a effects-based approach, considering factors such as the dominant firm’s intent, the likelihood of foreclosure, and potential efficiency justifications.

Understanding these prohibited practices is essential for businesses operating in Singapore to develop effective compliance strategies and navigate the competitive landscape successfully. In the following sections, we will explore exemptions to these prohibitions and delve deeper into the enforcement mechanisms and compliance considerations for businesses.

VI. Exemptions and Block Exemptions

While Singapore’s competition law prohibits various anti-competitive practices, it also recognizes that certain agreements or conduct may have pro-competitive effects or broader economic benefits. To address this, the Competition Act provides for several exemptions and exclusions. Understanding these exemptions is crucial for businesses to navigate the regulatory landscape effectively.

1. Net economic benefit exemption

The Competition Act allows for individual exemptions from the prohibition on anti-competitive agreements if they can be shown to have net economic benefits. This exemption is provided under Section 41 of the Act.

Key aspects of the net economic benefit exemption:

– Applicability: Applies to agreements that would otherwise infringe Section 34 (prohibition of anti-competitive agreements)

– Criteria: The agreement must contribute to improving production or distribution, or promoting technical or economic progress

– Consumer benefit: A fair share of the resulting benefits must be passed on to consumers

– Indispensability: The restrictions must be indispensable to achieving the benefits

– No elimination of competition: The agreement must not eliminate competition in respect of a substantial part of the goods or services in question

Businesses seeking this exemption must apply to the CCCS, providing detailed evidence to support their case. The CCCS conducts a thorough economic analysis to determine whether the criteria are met.

2. Vertical agreements block exemption

Singapore has implemented a block exemption for certain vertical agreements, recognizing that many such agreements can have pro-competitive effects. This exemption is provided through the Competition (Block Exemption for Vertical Agreements) Order.

Key features of the vertical agreements block exemption:

– Scope: Covers agreements between businesses operating at different levels of the production or distribution chain

– Market share threshold: Applies to agreements where the market share of both the supplier and the buyer does not exceed 25% in their respective markets

– Excluded restrictions: Certain hardcore restrictions, such as resale price maintenance, are not covered by the exemption

– Duration: The current block exemption order is valid until 2025, subject to potential renewal

This block exemption significantly reduces the compliance burden for many businesses, particularly SMEs, in structuring their distribution arrangements.

3. Other exemptions and exclusions

The Competition Act provides for several other exemptions and exclusions, reflecting policy considerations and specific sector needs:

a) Statutory exemptions:

   – Agreements required by law or to comply with legal requirements

   – Agreements necessary to avoid conflict with international obligations

   – Agreements which have the objective of national or public interest

b) Sector-specific exclusions:

   – Certain activities in the postal services sector

   – Specified activities of the clearing house for banks

   – Vertical agreements in the liner shipping industry (subject to specific conditions)

c) De minimis exemption:

   – Agreements between parties with a combined market share not exceeding 20% (for competitors) or 25% (for non-competitors) are generally considered to have no appreciable adverse effect on competition

d) Services of general economic interest:

   – Undertakings entrusted with the operation of services of general economic interest or having the character of a revenue-producing monopoly are exempt to the extent that the application of the Act would obstruct the performance of their assigned tasks

e) Mergers with net economic efficiencies:

   – Mergers that would otherwise be prohibited may be allowed if they can be shown to result in net economic efficiencies

These exemptions and exclusions provide important flexibility in the application of competition law, allowing for a balanced approach that considers both the need to protect competition and other policy objectives. Businesses should carefully assess their agreements and practices against these exemptions to determine their compliance status and potential need for notification to the CCCS.

Understanding and properly utilizing these exemptions can provide significant strategic advantages for businesses operating in Singapore, allowing them to structure their operations and agreements in ways that maximize efficiency while remaining compliant with competition law.

VII. Merger Control Regime

Singapore’s merger control regime is a critical component of its competition law framework, designed to prevent structural changes in the market that could substantially lessen competition. This section explores the key aspects of the merger control process in Singapore.

1. Notification thresholds and procedures

Singapore operates a voluntary notification system for mergers, which means that parties to a merger are not legally required to notify the CCCS. However, the CCCS has the power to investigate and take action against anti-competitive mergers, whether notified or not.

Key aspects of the notification system:

– Voluntary notification: Parties may choose to notify the CCCS if they believe their merger may raise competition concerns

– Indicative thresholds: While not mandatory, the CCCS provides indicative thresholds to guide businesses:

  * Combined market share of 20% or more

  * Combined market share of 20% to 40% and post-merger market share of the three largest firms of 70% or more

– Two-phase review process:

  * Phase 1: Initial review (30 working days)

  * Phase 2: In-depth assessment (120 working days, extendable)

– Fees: Notification fees apply, with different rates for Phase 1 and Phase 2 reviews

2. Substantive assessment criteria

The CCCS employs a “substantial lessening of competition” (SLC) test to assess mergers. This involves a comprehensive analysis of various factors to determine the likely impact of the merger on competition in the relevant market(s).

Key factors considered in the SLC assessment:

– Market definition and market shares

– Concentration levels and changes in market structure

– Barriers to entry and expansion

– Countervailing buyer power

– Eliminating a maverick firm

– Coordinated effects (increased likelihood of collusion)

– Vertical effects (foreclosure concerns in vertical mergers)

– Conglomerate effects (portfolio power in conglomerate mergers)

– Efficiencies and net economic benefits

The CCCS adopts a forward-looking approach, considering both current market conditions and likely future developments.

3. Commitments and remedies

If the CCCS identifies competition concerns, it may accept commitments from the merging parties to address these issues. Alternatively, it may impose remedies as conditions for clearing the merger.

Types of commitments and remedies:

– Structural remedies:

  * Divestiture of business units or assets

  * Licensing of intellectual property rights

– Behavioral remedies:

  * Access commitments (e.g., to essential facilities or key technology)

  * Firewall arrangements to prevent information sharing

  * Non-discrimination obligations

– Hybrid remedies: Combinations of structural and behavioral measures

The CCCS generally prefers structural remedies as they provide a clear-cut solution to competition concerns. However, the appropriate remedy will depend on the specific circumstances of each case.

VIII. Enforcement and Penalties

Effective enforcement is crucial to the success of any competition law regime. This section examines the CCCS’s enforcement powers, the leniency program, and the penalties for infringements.

1. CCCS investigative powers

The CCCS possesses broad investigative powers to enforce the Competition Act effectively:

– Power to require production of documents and information

– Authority to enter premises with or without a warrant

– Ability to conduct interviews and take statements from individuals

– Power to seal business premises and documents

– Authority to make copies or take possession of relevant documents

These powers enable the CCCS to gather evidence of potential infringements and conduct thorough investigations.

2. Leniency program

Singapore’s leniency program is a key tool in detecting and deterring cartel activity. It offers partial or total immunity from financial penalties to businesses that come forward with information about their involvement in cartel activities.

Key features of the leniency program:

– Full immunity for the first applicant to provide sufficient information about a cartel, subject to certain conditions

– Partial leniency (up to 100% reduction in financial penalties) for subsequent applicants

– Leniency Plus: Additional reduction for companies that disclose involvement in a separate cartel

– Marker system: Allows applicants to secure their place in the leniency queue while gathering additional information

The leniency program has been instrumental in uncovering several significant cartel cases in Singapore.

3. Financial penalties and other sanctions

The CCCS has the power to impose substantial financial penalties for infringements of the Competition Act:

– Maximum penalty: Up to 10% of the turnover of the business in Singapore for each year of infringement, up to a maximum of three years

– Factors considered in setting penalties:

  * Seriousness of the infringement

  * Turnover of the business in the relevant market

  * Duration of the infringement

  * Aggravating and mitigating factors

– Other potential consequences:

  * Directive to modify or terminate agreements

  * Behavioral or structural remedies to address anti-competitive conduct

  * Private actions for damages by affected parties

In addition to financial penalties, the reputational damage and potential for private follow-on actions serve as significant deterrents to anti-competitive behavior.

IX. Compliance and Risk Management for Businesses

Given the significant consequences of competition law infringements, businesses operating in Singapore must prioritize compliance and effective risk management. This section outlines key strategies for developing a robust competition law compliance program.

1. Developing an effective compliance program

A well-designed compliance program is essential for preventing competition law infringements and mitigating risks. Key elements of an effective program include:

– Clear policy statement and commitment from top management

– Appointment of a compliance officer or team

– Comprehensive compliance manual and guidelines

– Regular training for employees, especially those in high-risk positions

– Mechanisms for reporting potential infringements

– Procedures for handling dawn raids and investigations

– Regular review and updating of the compliance program

Tailoring the program to the specific risks and needs of the business is crucial for its effectiveness.

2. Conducting internal audits and risk assessments

Regular internal audits and risk assessments help businesses identify potential compliance issues and address them proactively:

– Review of agreements and business practices for compliance

– Assessment of market positions and potential dominance issues

– Evaluation of pricing strategies and discount schemes

– Analysis of information exchanges with competitors

– Review of merger and acquisition activities for potential notification requirements

These assessments should be conducted periodically and whenever there are significant changes in the business or market conditions.

3. Training and education for employees

Ongoing training and education are vital to ensure that employees at all levels understand competition law requirements and their role in maintaining compliance:

– Tailored training programs for different departments and roles

– Regular refresher courses to keep knowledge up-to-date

– Practical guidance on identifying and handling competition law risks

– Case studies and scenario-based training to enhance understanding

– Integration of competition law compliance into employee onboarding and performance evaluations

Effective training helps create a culture of compliance throughout the organization.

X. Recent Developments and Future Trends

Singapore’s competition law landscape continues to evolve in response to changing market dynamics and global trends. This section explores recent developments and emerging issues that businesses should be aware of.

1. Digital markets and e-commerce

The rapid growth of digital markets and e-commerce has presented new challenges for competition regulation:

– Market definition and assessment of market power in digital markets

– Addressing potential anti-competitive effects of algorithms and big data

– Scrutiny of digital platforms and potential abuse of dominance

– Merger control in fast-moving digital markets

The CCCS has been proactive in addressing these issues, conducting market studies and adapting its analytical frameworks to the digital economy.

2. Cross-border enforcement cooperation

As businesses increasingly operate across borders, competition authorities are enhancing their international cooperation:

– Increased information sharing and coordination in cross-border investigations

– Participation in international networks such as the International Competition Network (ICN)

– Bilateral and multilateral cooperation agreements with other competition authorities

– Harmonization of competition laws and procedures in the ASEAN region

This trend towards greater international cooperation has implications for multinational businesses operating in Singapore and the wider region.

3. Emerging issues in competition law

Several emerging issues are likely to shape the future of competition law in Singapore:

– Sustainability and competition law: Balancing environmental considerations with competition principles

– Labor markets: Increased focus on competition issues in labor markets, such as no-poach agreements

– Innovation considerations: Greater emphasis on innovation effects in merger assessments and abuse of dominance cases

– Intersection with data protection and consumer protection laws

Businesses should stay informed about these developments and their potential impact on competition law compliance.

XI. Practical Considerations for Businesses Operating in Singapore

For businesses operating in Singapore, navigating the competition law landscape requires a proactive and strategic approach. This section provides practical guidance on key considerations for ensuring compliance and managing competition law risks.

1. Due diligence and risk assessment

Conducting thorough due diligence and risk assessments is crucial for identifying and mitigating competition law risks:

– Regular review of business practices and agreements

– Assessment of market positions and potential dominance issues

– Evaluation of proposed mergers and acquisitions for potential competition concerns

– Analysis of pricing strategies and discount schemes

– Review of information sharing practices with competitors and industry associations

Implementing a systematic approach to risk assessment can help businesses identify potential issues before they escalate into legal problems.

2. Structuring agreements and business practices

Careful structuring of agreements and business practices can help minimize competition law risks:

– Drafting clear and compliant distribution agreements

– Implementing safeguards in joint ventures and collaborations with competitors

– Developing pricing and rebate schemes that avoid exclusionary effects

– Establishing protocols for participation in trade associations and industry meetings

– Implementing compliance safeguards in digital and e-commerce operations

Seeking legal advice when structuring complex agreements or entering new markets can provide valuable protection against potential infringements.

3. Navigating merger control processes

For businesses considering mergers or acquisitions in Singapore, navigating the merger control process effectively is essential:

– Early assessment of whether the transaction may raise competition concerns

– Consideration of voluntary notification based on the CCCS’s indicative thresholds

– Thorough preparation of merger notifications, including comprehensive market analysis

– Proactive engagement with the CCCS during the review process

– Preparation of potential remedies to address competition concerns

Effective management of the merger control process can help avoid delays and increase the likelihood of obtaining clearance for transactions.

XII. Conclusion

1. Recap of key points

Singapore’s competition law framework, centered around the Competition Act and enforced by the CCCS, provides a robust structure for promoting fair competition and preventing anti-competitive practices. Key aspects of this framework include:

– Prohibition of anti-competitive agreements, abuse of dominance, and anti-competitive mergers

– A nuanced approach to enforcement, with various exemptions and block exemptions

– A voluntary merger notification system with a substantive “substantial lessening of competition” test

– Strong investigative and enforcement powers, including significant financial penalties for infringements

– A leniency program to encourage the reporting of cartel activities

2. Importance of staying informed and compliant

As Singapore’s competition law continues to evolve in response to changing market dynamics and global trends, businesses must remain vigilant and adaptive in their approach to compliance:

– Regularly update compliance programs and risk assessment procedures

– Stay informed about emerging issues and regulatory developments

– Invest in ongoing training and education for employees

– Seek expert legal advice when navigating complex competition law issues

By prioritizing competition law compliance and adopting a proactive approach to risk management, businesses can not only avoid potential legal and financial consequences but also contribute to a fair and competitive business environment in Singapore.

In an increasingly interconnected global economy, with Singapore positioning itself as a key hub for business in Asia, understanding and complying with the nation’s competition law is not just a legal necessity but a strategic imperative for business success.

Some references:

  • Competition Act (Chapter 50B), Republic of Singapore, 2004 (revised 2006).
  • Ong, B. “The Origins, Objectives and Structure of Competition Law in Singapore.” World Competition, vol. 29, no. 2, 2006, pp. 269-284.
  • Competition and Consumer Commission of Singapore. “CCCS Guidelines on the Section 34 Prohibition.” 2016.
  • Cheng, T.K. “The Competition Law and Policy of Singapore.” The Political Economy of Competition Law in Asia, 2013, pp. 172-196.
  • Competition and Consumer Commission of Singapore v. Grab Inc. and Uber Technologies, Inc. [2018] SGCCS 3.
  • Lua, A.C. “Merger Control in Singapore: Law and Practice.” Journal of Antitrust Enforcement, vol. 7, no. 1, 2019, pp. 121-149.
  • Competition and Consumer Commission of Singapore. “CCCS Guidelines on the Substantive Assessment of Mergers.” 2016.
  • Teo, Y.Y. “Cartel Enforcement in Singapore: From Leniency to Penalties.” Singapore Academy of Law Journal, vol. 28, 2016, pp. 494-530.
  • Competition and Consumer Commission of Singapore. “CCCS Guidelines on the Appropriate Amount of Penalty in Competition Cases.” 2016.
  • Chong, S.Y. and Chao, X. “Digital Platforms and Competition Law in Singapore.” Singapore Academy of Law Journal, vol. 31, 2019, pp. 359-385.
  • ASEAN Secretariat. “Handbook on Competition Policy and Law in ASEAN for Business.” 2017.
  • Lim, C.H. and Ong, D.W. “Competition Law and Policy in Singapore.” Cambridge University Press, 2020.
  • Competition and Consumer Commission of Singapore. “E-commerce Platforms Market Study.” 2020.
  • Ong, B. “The Interface Between Competition Law and Intellectual Property in Singapore.” International Review of Intellectual Property and Competition Law, vol. 51, 2020, pp. 709-740.
  • Competition and Consumer Commission of Singapore. “Annual Report 2023.” 2024.

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