MDPPACPB Regulations

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Requirement 
Description 
Compliance Status 
(Tick Box) 
Availability of Staff Applicant has made officers, employees, and agents available for 
interviews and testimony as requested by the Authority. 
☐ Complied ☐ Not 
Complied 
Continuous 
Disclosure 
Applicant has provided additional documents or information discovered 
after the initial application. 
☐ Complied ☐ Not 
Complied 
Confidentiality 
Applicant has maintained confidentiality of the leniency application and 
has not disclosed its existence without prior consent of the Authority. 
☐ Complied ☐ Not 
Complied 
Compliance 
Measures 
Applicant has implemented or strengthened internal compliance 
programmes to prevent recurrence. 
☐ Complied ☐ Not 
Complied 
No Obstruction 
Applicant has not obstructed or interfered with the Authority’s 
investigation. 
☐ Complied ☐ Not 
Complied 
 
 
4. Procedural Cooperation 
 
Requirement 
Description 
Compliance Status 
(Tick Box) 
Timely Responses 
Applicant has responded to all Authority requests within 
prescribed deadlines. 
☐ Complied ☐ Not 
Complied 
Marker Preservation 
Applicant has confirmed priority marker status (if first 
applicant) by submitting required materials within 
stipulated timelines. 
☐ Complied ☐ Not 
Complied 
Settlement Integration 
(if applicable) 
Applicant has complied with obligations under the 
Settlement Procedure Guideline if applying for combined 
leniency and settlement. 
☐ Complied ☐ Not 
Complied 
 
5. Final Stage Obligations 
 
Requirement 
Description 
Compliance Status 
(Tick Box) 
Final Verification 
Applicant has signed a verification statement confirming the 
completeness and truthfulness of its disclosures before issuance of the 
Authority’s final decision. 
☐ Complied ☐ Not 
Complied 
Implementation of 
Remedies 
Applicant has complied with remedial, structural, or behavioural 
commitments imposed by the Authority. 
☐ Complied ☐ Not 
Complied 
 
6. Declaration 
 
The applicant acknowledges that failure to comply with any of the above 
obligations may result in: 
(a) Reduction of fine reduction benefits; 
(b) Revocation of leniency status; and 
(c) Exposure to full penalties under the Petroleum Industry Act, 2021, the 
FCCPA, and applicable Regulations. 
 
 
Schedule 4(D): Confidentiality and Disclosure Protocol 
Confidentiality and Disclosure Protocol for Leniency Applications 
 
(Issued pursuant to the Leniency Policy for the Midstream and Downstream 
Petroleum Industry Competition Regulations, 2025)