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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Final Leniency Decision Template 
 
(Issued pursuant to the Leniency Policy for the Midstream and Downstream 
Petroleum Industry Competition Regulations, 2025) 
 
 
 
[Official Letterhead of the Authority] 
 
Ref No.: __________________________ 
Date: _____________________________ 
 
To: 
[Name of Applicant / Company] 
[Registered Address] 
 
 
Subject: Final Leniency Decision – Petroleum Midstream and Downstream 
Competition Regulations 
 
 
1. Background 
 
1.1 The Nigerian Midstream and Downstream Petroleum Regulatory Authority 
(“the Authority”), acting pursuant to 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), received a Leniency Application from [Applicant] dated ____________. 
 
1.2 A Conditional Leniency Letter was issued to the Applicant on ____________, 
granting provisional eligibility subject to cooperation obligations. 
 
1.3 Following the completion of the Authority’s investigation and adjudication 
process, the Authority now issues this Final Leniency Decision. 
 
 
2. Findings of Fact 
 
2.1 The Authority finds that: 
(a) The Applicant participated in [description of anti-competitive conduct: 
e.g., cartel agreement, bid-rigging, market allocation, price fixing, etc.]; 
(b) The Applicant has admitted liability and provided detailed information 
regarding the nature, scope, and duration of the conduct; 
(c) The Applicant provided substantial cooperation, including disclosure of 
documents, testimony of employees, and access to relevant records; and 
(d) The Applicant ceased participation in the infringing conduct as of [date].