Library / PETROLEUM INDUSTRY ACT, NO. 6, 2021 MIDSTREAM AND DOWNSTREAM PETROLEUM PREVENTION OF ANTICOMPETITIVE PRACTICES AND BEHAVIOUR REGULATIONS, 2026 ARRANGEMENT OF REGULATIONS

PETROLEUM INDUSTRY ACT, NO. 6, 2021 MIDSTREAM AND DOWNSTREAM PETROLEUM PREVENTION OF ANTICOMPETITIVE PRACTICES AND BEHAVIOUR REGULATIONS, 2026 ARRANGEMENT OF REGULATIONS

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4.2 The combined benefit of leniency and settlement shall not exceed 100% 
immunity from fines. 
 
 
5. Exclusions 
 
5.1 No reduction shall be granted where: 
(a) The applicant was the ringleader or coercer of the cartel; 
(b) The applicant provides false or misleading information; or 
(c) The applicant fails to cease participation in the infringing conduct 
 
 
Schedule 4(C): Cooperation Obligations Checklist 
 
Cooperation Obligations Checklist for Leniency Applicants 
 
(Issued pursuant to the Leniency Policy for the Midstream and Downstream 
Petroleum Industry Competition Regulations, 2025) 
 
 
1. Purpose 
 
This Checklist sets out the cooperation obligations that a leniency applicant 
must fulfil in order to qualify for and retain leniency benefits under the 
Midstream and Downstream Petroleum Industry Competition Regulations. 
Compliance with these obligations shall be monitored continuously by the 
Authority, and failure to meet any requirement may result in reduction or 
revocation of leniency benefits. 
 
 
2. General Obligations 
Requirement 
Description 
Compliance Status 
(Tick Box) 
Immediate 
Cessation 
Applicant has ceased participation in the anti-competitive conduct 
upon filing the application. 
☐ Complied ☐ Not 
Complied 
Full Disclosure 
Applicant has made a full and truthful disclosure of all facts known to 
it relating to the infringement. 
☐ Complied ☐ Not 
Complied 
Submission of 
Evidence 
Applicant has submitted all documentary, electronic, financial, and 
testimonial evidence in its possession. 
☐ Complied ☐ Not 
Complied 
Admission of Liability Applicant has provided a clear written admission of its role in the 
infringement. 
☐ Complied ☐ Not 
Complied 
No Concealment 
Applicant has not destroyed, concealed, or tampered with 
evidence. 
☐ Complied ☐ Not 
Complied 
No 
Misrepresentation 
Applicant has not provided false or misleading information. 
☐ Complied ☐ Not 
Complied 
 
 
3. Ongoing Cooperation