MDPPACPB Regulations

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7.2 The identity of applicants and details of evidence shall not be published 
unless: 
    (a) The applicant consents; or 
    (b) Disclosure is mandated by law or required for deterrence in cases of 
egregious conduct. 
 
 
8. Applicant’s Obligations 
 
8.1 Applicants must: 
    (a) Clearly identify and justify claims of confidentiality at the time of 
submission; 
    (b) Provide both confidential and non-confidential versions of documents; 
and 
    (c) Refrain from unauthorised disclosure of their own leniency application. 
 
 
9. Breach of Confidentiality 
 
9.1 If the Authority breaches its confidentiality obligations, the applicant may: 
    (a) Seek review or appeal under applicable law; and 
    (b) Be entitled to mitigation of any prejudice suffered, including adjustments 
to settlement or enforcement measures. 
 
9.2 If an applicant breaches confidentiality (e.g., discloses its own application 
without authorisation), the Authority may revoke leniency status. 
 
 
10. Review and Amendment 
 
This Protocol shall be reviewed every three (3) years, or earlier if required by 
legal developments, international practice, or operational necessity. 
 
 
 
 
Schedule 4(E): Model Conditional Leniency Letter 
 
 
 
Model Conditional Leniency Letter 
 
(Issued pursuant to the Leniency Policy for the Midstream and Downstream 
Petroleum Industry Competition Regulations, 2025) 
 
 
[Official Letterhead of the Authority]