As a leading manufacturer of roof windows, VELUX very keenly observes the rules and demands on fair competition that competition authorities in the European markets and in the EU make to a market leading company. VELUX complies with all national and international rules in this area and continuously monitors the state of law.
In 1996 VELUX implemented a comprehensive Compliance Programme, which is updated continuously. The objective of this programme is to ensure that all sales companies are aware of their obligations in terms of competition rules. The Compliance Programme consists – among others – of the following elements:
- Our compliance policy
- Instructions on compliance with competition rules
- An annual management declaration
Because of our position in the European markets, VELUX is continuously in contact with the competition authorities in both Denmark and the EU. Our relations with these authorities are characterised by openness and cooperativeness. VELUX has thus for a number of years willingly made all information available when approached by the competition authorities.
Competition Law Compliance Programme
VELUX A/S and all VELUX companies follow our owner’s, VKR Holding A/S’, Competition Law Compliance Policy. This policy describes our approach in relation to customers, competitors, mergers & acquisitions, and other relevant issues, such as trade conditions. The main content of the Competition Law Compliance Policy is:
It is the overall competition law compliance policy that all VKR Group companies, at all times, comply with the relevant national and international antitrust & competition law requirements (e.g. EU Competition Law).
In order to secure compliance, a Compliance Programme has been set up. It consists of compliance measures such as:
- Training, e.g. workshops, seminars, and training programmes, on antitrust and competition law (and changes therein)
- Current instructions and guidelines by the General Counsel of our parent company on competition law issues
- Personal annual declarations of compliance to be signed by all relevant managers and directors
- Mock-up dawn raids (to secure co-operation with the authorities in case of a dawn raid)
- Competition law audits by the General Counsel of our parent company
- Competition law due diligence at all mergers & acquisitions
- Approval procedure by competition law specialists on trade conditions and sales & delivery terms
- Involvement of the General Counsel of our parent company in all cases of co-operation and knowledge sharing with competitors
- Involvement of the General Counsel of our parent company in all cases of non-competition clauses and other restrictive (in terms of competition) agreements/clauses.
The General Counsel monitors the competition law compliance and continuously assesses the compliance procedures.
About the competition rules in the EC Treaty
To ensure fair competition throughout the EU and to further the creation of the Single EU Market, the EC Treaty establishes the principle that market conditions throughout the EU shall not be distorted through anti-competitive agreements, arrangements or practices.
The competition rules in the EC Treaty are based mainly on Articles 81 and 82. Article 81 is prohibiting anti-competitive agreements or concerted practices between independent companies whereas Article 82 is prohibiting dominant companies abusing their market strength.