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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Ref No.: __________________________ 
Date: _____________________________ 
 
To: 
[Name of Applicant / Company] 
[Registered Address] 
 
 
Subject: Conditional Leniency Letter – Petroleum Midstream and Downstream 
Competition Regulations 
 
1. 
The Nigerian Midstream and Downstream Petroleum Regulatory 
Authority (the “Authority”), acting under the Petroleum Industry Act, 2021, the 
Midstream and Downstream Petroleum Industry Competition Regulations, 
2025, and the Leniency Policy (harmonised with the FCCPC Leniency Rules, 
2022), hereby acknowledges receipt of your Leniency Application dated 
____________ (the “Application”). 
 
2. 
Based on the information provided to date, the Authority has 
determined that you are provisionally eligible for conditional leniency status, 
subject to full compliance with the obligations outlined below. 
 
 
A. Provisional Benefits 
 
3. 
Subject to final determination, the Applicant shall be entitled to: 
    (a) Priority marker status as the [First/Second/Third/Subsequent] Applicant; 
    (b) Potential fine reduction within the range of ________% (as set out in 
Schedule II of the Leniency Policy); 
    (c) Consideration for immunity from prosecution or sanctions to the extent 
permitted by law; and 
    (d) Recognition of cooperation in any related settlement proceedings. 
 
 
B. Applicant’s Obligations 
 
4. 
In order to maintain eligibility for leniency, the Applicant must: 
    (a) Cease all participation in the anti-competitive conduct immediately; 
    (b) Provide full, continuous, and truthful cooperation with the Authority, 
including disclosure of all relevant facts, documents, and witnesses; 
    (c) Make officers, employees, and agents available for interviews and 
testimony as requested; 
    (d) Submit both confidential and non-confidential versions of documents; 
    (e) Refrain from destroying, concealing, or falsifying any evidence; and 
    (f) Maintain strict confidentiality regarding this Application and this Letter. 
 
 
C. Confidentiality Assurances 
 
5. 
The Authority shall treat all information provided in connection 
with this Application as confidential, subject to: 
    (a) Legal obligations under court order or statutory requirement;