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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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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)