Resolution of Board of Director for Submitting Roc Forms

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Resolution of Board of Director for Submitting Roc Forms Powered By Docstoc
					                                 December 2008

Title:                 NHS London Competition Dispute Resolution
                       Process
Agenda item:           7                   Paper                       G
Executive Summary:     In September, the Board was presented with a paper providing an
                       overview of the new system management policy context, and the
                       role of SHAs within it. It updated the Board on steps being taken to
                       meet our new responsibilities, including the development of a
                       competition dispute resolution process. This paper asks the Board
                       to agree the final version of that process, including governance
                       arrangements.

Action requested:      For agreement       Was legal advice            No
                                           received?

Equality Impact        N/A                 Risk assessment             System
Assessment complete?                       undertaken?                 management has
                                                                       been assessed for
                                                                       risk and is on the
                                                                       risk register.

Name of author:        Hannah Farrar
Title:                 Director, Strategy and System Management
Date:                  December 2008

Director name:         Hannah Farrar
Director title:        Director, Strategy and System Management
NHS London Competition Dispute Resolution Process
1. The new Strategy and System Management directorate is starting to develop NHS
   London’s system management capability. As well as scoping the longer-term functional
   requirements, one of our first priorities has been to produce a competition dispute
   resolution process. This paper asks the Board to agree a final version of this process,
   which is attached at Annex A.

2. The Principles and Rules for Co-operation and Competition (PRCC) came into operation on
   1 April 2008. PCTs, as commissioners, are responsible for ensuring that different types of
   provider are treated fairly. The SHA’s role is to ensure that PCTs’ decisions are fair,
   transparent and well informed, and SHA boards must have appropriate governance
   arrangements in place to avoid potential or perceived conflicts of interest. As a
   consequence, NHS London (along with all SHAs) also has a role in handling complaints
   concerning breaches of the PRCC.

3. The DH has set out the high level process by which complaints should be handled. The
   design of the process is based on the principle of subsidiarity – disputes should be
   resolved at the most local level possible. The first port of call for the complainant
   (provider/bidder) is the PCT. If the dispute is not successfully resolved at this level, the
   complaint can then be heard by an SHA-level panel. If the complaint is still not satisfactorily
   resolved, it can be referred to the national Co-operation and Competition Panel (CCP). This
   is a non-statutory body which the Government has established, recognising there may be
   times when competition issues cannot be resolved locally. It will provide independent
   advice to the Secretary of State and Monitor. Lord Carter of Coles was appointed as the
   national CCP’s chair from 1 October 2008, and the panel will formally start work from 1
   January 2009. The national CCP will also handle a number of ‘reserved matters’, the most
   critical of which is a competition analysis of proposed mergers and acquisitions.

4. The national CCP will consider issues only when action to resolve matters locally has been
   exhausted. To this end the PCTs and SHA are required to set up and run a Competition
   Dispute Resolution Process and Competition Dispute Resolution Panel, to manage
   disputes at a local level before they are referred to the national CCP.

5. NHS London developed a draft competition dispute resolution process. This was shared
   and moderated across the SHAs, with input from the DH, to ensure a consistency of
   approach. The SHAs have also sought collective legal advice to ensure processes are
   robust.

6. Following the Board’s agreement of the draft process in September, an informal
   consultation was held with commissioners and providers across London. A small number of


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   responses were received, from a combination of commissioners and providers. The
   process has now been revised where appropriate in light of these responses, and following
   further discussions with other SHAs.

7. It is proposed that the Board should delegate authority to the panel to deal with complaints
   under the Competition Dispute Resolution Process (although the panel would be able to
   refer cases back to Board for decision if necessary). The Director of Strategy and System
   Management will report the outcome of any panel hearing to the Board for information.

8. Permanent membership of the panel will be as follows:
        • Non-executive director (as panel Chair)
        • Director of Strategy and System Management
        • Assistant Director – System Management

9. In addition to this, depending on the nature of the complaint, the panel is like to draw on:
          • Other members of the SHA with relevant knowledge and expertise
          • External experts, which could include legal (including equality legislation),
              regulatory, economic or other advice.

10. We recommend that the Board approves the London Competition Dispute Resolution
    Process attached at Annex A, including the governance arrangements set out at
    paragraphs 7-8 above.




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NHS London
Competition Dispute Resolution Process

Purpose of Competition Dispute Resolution Process

1.      NHS London is establishing a competition dispute resolution process in
        line with its responsibilities under The Principles and Rules for Co-
        operation and Competition1 published in the Operating Framework,
        2008-09.

2.      This process is published for the purpose of transparency and to ensure
        commissioners and providers/bidders are clear on what constitutes a
        ‘dispute’ and what action NHS London will take in light of one.

3.      This process is written to be in line with DH guidelines and consistent
        with the competition dispute resolution processes of the other strategic
        health authorities (SHAs).


Background

4.      The Principles and Rules for Co-operation and Competition (PRCC) set
        out the expectations on commissioners and providers to work in a more
        open system, characterised by a stronger purchaser/provider split, more
        plurality of provision, and a greater degree of competition for service
        provision.

5.      The PRCC are core to the system management of the NHS. System
        management incorporates the series of values, relationships, contracts
        and rules which are designed to promote patient and taxpayer interests
        within the NHS. These are essential elements of the NHS reform
        programme, which puts patients at the heart of driving change in health
        services – directly through choice, and indirectly through influencing and
        shaping commissioning.

6.      Consequently, a central element of NHS London’s system management
        function is the handling of competition disputes. The principles of how we
        approach this are based on guidance contained in a variety of policy
        documents, most recently:
        •    the consultation paper on The future regulation of health and adult
             social care in England – response to consultation, October 2007;
        •    the Operating Framework for 2008/09, December 2007, and in
             particular, the PRCC issued with it;
        •    the Framework for Managing Choice, Cooperation and Competition,
             July 2008; and,
        •    the PCT Procurement Guide for Health Services, July 2008.




1
    Annex D, The Operating Framework, December 2007
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7.   These policy documents set out the vision for a health system which has
     quality, equity and access at its core and which embraces patient choice,
     proactive commissioning, quality-based regulation and appropriate
     provider-side competition as key elements in the delivery of this vision.
     They also represent a step change in the policy context.


Objectives of the Competition Dispute Resolution Process

8.   It is important that where possible, disputes are resolved locally,
     preventing the need for upward referral. It is to be hoped that most
     disputes will be resolved at PCT level. Where there is need for
     escalation, the objectives of the NHS London Competition Dispute
     Resolution Process (LC-DRP) are:
     • to resolve competition disputes transparently, fairly and consistently;
     • to provide confidence to parties that the process is fair and
       transparent, enhancing willingness to participate in the market;
     • to mitigate risks and protect the reputation of the NHS;
     • to be compliant with the acceptance criteria of the national
       Cooperation and Competition Panel (CCP) once they are developed;
       and,
     • to prevent where possible legal challenge or other external referral
       processes.


Principles by which the process will operate

9.   NHS London will follow a set of principles outlined by the Department of
     Health:

     Transparency
     Any process that is intended to resolve disputes must be transparent.
     This includes publishing the process in advance, communicating
     progress to all relevant stakeholders, making declarations of interests
     and publishing decisions.

     Objectivity
     Dispute resolution must be based, wherever possible, on objective
     information and criteria. An appropriate audit trail will be maintained for
     all disputes raised with NHS London.

     Proportionality
     Providers/bidders should only begin a formal dispute process on issues
     of material importance. The resources used to deal with each dispute
     must be proportionate to the significance of the dispute.

     Non-discrimination
     NHS London will not favour any part of the system over any other.

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     Accountability
     The NHS London Board is accountable for the competition dispute
     resolution process and the decisions of the SHA panel. PCT Boards are
     expected to act on the decisions of the panel.

     Subsidiarity
     Decisions should be made by the lowest competent authority. NHS
     London expects competition disputes to be raised with, and resolved by
     PCTs wherever possible.

     Consistency
     NHS London will ensure internal consistency when resolving disputes.
     All strategic health authorities have agreed to co-operate to ensure
     national consistency in the handling of disputes.

     No double jeopardy
     The process will ensure, where possible, that commissioners will not be
     held to account for the same issue, by more than one organisation.
     Complainants will be required to inform NHS London about, and the
     nature of, any engagement with other bodies.


Criteria for accepting disputes

10. The panel will only accept disputes that meet the following criteria:
     •    The complaint must relate to a breach of the Principles and Rules
          for Co-operation and Competition (or any future competition policy
          which may be issued by the Department of Health).
     •    There must be a full and frank disclosure of all relevant and
          applicable information. (This does not preclude the panel from
          asking for further information as it requires).
     •    Individuals connected to the complaint should be able to make
          themselves available to provide further evidence as required.
     •    There must be evidence that the party bringing the complaint has
          made reasonable effort to have this resolved at PCT level, or can
          demonstrate that this was inappropriate, and that all other attempts
          at resolution have been completed.
     •    The complaint must relate to an incident which has occurred in the
          last six months.
     •    No legal action has commenced or will commence during the
          course of NHS London’s consideration of the dispute.
     •    The dispute must not be not trivial, vexatious or an abuse of NHS
          London’s procedures.
     •    There must be adequate time to hear the complaint.
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      •      NHS London should be the best placed organisation to resolve the
             dispute (over other regulatory bodies).


PCT processes

11.       London’s PCTs will be required to publish and practice a competition
          dispute resolution process which must follow the principles of London’s
          policy and must be compliant with the PRCC. In all cases the process
          must be transparent and published on the PCT’s web site.

12.       The PCT will be the first port of call for dealing with disputes, and the
          hope is that most complaints will be successfully resolved at this stage.

13.       All PCT’s will have a named individual (detailed on their web site) to
          whom complaints may be sent. They will also have a dispute resolution
          panel.

14.       PCT websites will further provide: guidelines on how to bring a
          complaint; forms for submitting complaints; criteria for acceptance; and,
          a number to call for assistance.

15.       PCT processes must be objectively independent, and be fit for purpose
          to cater for disputes that involve PCT provider arms.


The NHS London process

16.       As with London PCTs, NHS London will publish details on its website
          of the process, a ‘named individual’, forms required and helpline
          number. [The named individual will be the Assistant Director for
          System Management – currently being recruited.]The website will also
          advise on the need to resolve disputes locally either by mutual
          agreement or through the local PCT process. Timelines for raising and
          resolving disputes will also be made clear.

Stage 1: making the complaint

17.       Any complaint must be made in the first instance by means of a form
          available from the NHS London website (link).

18.       When a complaint is to be made, the form is filled in by the user and
          any additional evidence should be submitted to (mailbox) along with
          the complaint. An example of the form can be found at Annex A.

Stage 2: triage

19. Once the complaint is received, an assessment will be made of whether
    it is appropriate for the SHA to consider the complaint (or whether it
    should be referred back to the relevant PCT, or escalated directly to the
    national CCP).. It must be fully compliant with the acceptance criteria.
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     Consideration will also be given to whether there is sufficient evidence in
     support of the case and the extent to which local dispute resolution has
     been attempted. However, NHS London will assume good faith on the
     part of those bringing the complaint and will offer advice to those who are
     not fully compliant (either in terms of how to submit or other places to
     which the case can be taken).

20. If the complaint is to progress within the system, after passing all checks,
    a letter will be sent to all parties in the dispute with a contact number and
    case reference. If the complaint is rejected at this stage the complainant
    will be informed in writing.

21. The triage stage will take no longer then five working days.

Stage 3: post-triage

22. The panel will have a preliminary discussion about the case and decide
    what evidence is required for a decision. The organisation against which
    the complaint has been made will be asked in writing to provide
    evidence. The panel will further decide if legal (or other expert) advice is
    needed. The panel may decide to request further evidence from either
    party in the case. In certain circumstances, the panel may commission
    an investigation to try and gather impartial evidence.

23. The panel will formally sit and review the case assessing both sides of
    the complaint. It is envisaged that this will be desk-based but this will be
    a matter for the Chair to decide.

Stage 4: decision

24. If the complaint is upheld the panel will write to both parties with the
    rationale for the decision and the necessary actions for both parties in
    resolving the dispute along with an action plan to ensure resolution is
    reached.

25. If the case is rejected both parties will be informed in writing of the
    reasons why and any lessons to be learned from the experience.

26. In some circumstances the panel may have to reserve judgement and
    recommend that it be referred to another body. This may occur if the
    decision is beyond the scope of the LC-DRP (and needs to be referred to
    either the national Co-operation and Competition Panel, or the Office of
    Fair Trading, or Competition Commission) or if there is insufficient
    evidence for the panel to reach a decision, again, a recommendation to
    refer may ensue.

27. Should a party to the original dispute not be satisfied by the process
    followed or the outcome reached, they will have a further opportunity to
    have the case heard by referring to the national Co-operation and
    Competition Panel.

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28. Following triage, the panel will take no longer then 3 months to resolve a
    dispute.



Appeals
29. If the complainant does not believe the case has been satisfactorily
    resolved (at either triage or final decision stage), they can appeal directly
    to the national Cooperation and Competition Panel. The complainant can
    appeal to the national CCP at any stage of the process if they think they
    have been unfairly treated.


Membership of the SHA Competition Dispute Resolution Panel

30. Managing competition disputes, as part of system management must
    now be seen as ‘core business’ for NHS London. Therefore, the panel
    will be made up of senior NHS London staff. To ensure the quality of the
    process there will be a non-executive Chair.

31. The panel make up will be as follows:
     •    Non-executive director (Chair)
     •    Director of Strategy and System Management
     •    Assistant Director - System Management (‘named individual’)

32. In addition to this, depending on the nature of the complaint the panel is
    likely to draw upon:
     • Other members of the SHA with relevant knowledge and expertise
     • Other external experts, which could include legal (including on
       equality legislation), regulatory, economic or other advice.

     The exact make up of the panel and advice to be taken by it will be
     decided by the permanent members once the triage stage has been
     completed.


Further information

33. If you require any further information in relation to the LC-DRP, please
    contact [named individual], the case manager for NHS London.




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Annex A


Competition Dispute Resolution Form
This form is for complaints relating to breaches of the Principles and Rules
of Cooperation and Competition. You should only complain to the SHA
relevant to the issue you are raising i.e. in the SHA region concerned, or
where the commissioner is based.

Where services are commissioned by one or more bodies, complaints should
be lodged with the lead commissioner. Complaints regarding national
providers should be lodged with the relevant SHA i.e. the SHA region where
the alleged infringement occurred. We reserve the right to delegate to another
SHA where they are better placed to resolve a given matter.

If you are complaining about a cross-boundary issue (i.e. involving more than
one SHA) you can complain to any relevant SHA, but we reserve the right to
nominate the lead SHA for the purpose of resolving the dispute.

The initial part of the form will enable you to review your complaint against our
entry criteria, and it will be necessary for you to complete this checklist
against our criteria to confirm you meet these, along with our terms and
conditions. By completing the form you are confirming that you consent to the
resolution of the complaint by way of the DRP. You are encouraged to raise
all issues within a reasonable timescale (and in any case within six months of
the incident occurring, as stipulated in the SHA acceptance criteria) in order
that the SHA can contemporaneously investigate the matter and the SHA will
attempt to resolve your complaint within our published timescales. Any
extension to the timescale will be by agreement with the parties concerned.

NHS London will send a version of this submission to the parties named in
your complaint. If your submission contains confidential information, you
should indicate this clearly for redaction. This form is to be used to lodge the
complaint and should contain only the detail necessary for an assessment to
be made. If further information is required, it will be requested.

We will disclose your business name to the company or individual about
whom you are complaining. NHS London recognises that there are some
circumstances in which complainants prefer to remain anonymous but that
may hinder the effectiveness of the investigation.

If your complaint meets our entry criteria and we decide to review your
complaint, we may publish details of the complaint, including your business
name, on our website. Please also not that any documents received by NHS
London may be subject to Freedom of Information Act disclosure.

In order for NHS London to process your complaint efficiently and effectively
please complete all the relevant fields with appropriate information.
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If you require further advice or assistance please contact:
Case Manager at [add e-mail]
Switchboard: 020 7932 3700
Direct Dial: 020 7932 XXXX

Yours sincerely,

Chair of the Competition Dispute Resolution Panel




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Competition dispute resolution
Stage 1 – Assessment against the entry criteria
Below is a list of questions which test whether your complaint is likely to meet
our entry criteria for assessment. If you cannot answer “yes” to all of these
questions, it is likely your complaint does not meet our entry criteria and the
panel will not be able to consider your complaint. If you need to discuss any
aspect of this, please click here to contact us

    1. We confirm that the content of the dispute is covered by the
     Principles and Rules for Co-operation and Competition (PRCC)

    2. We confirm that the information given in this form and
    throughout any subsequent investigation is a full and frank
    disclosure of all relevant and applicable information. (Please
    note, this does not preclude the SHA Dispute Resolution Panel
    from seeking further information as it requires.)

    3. We confirm that any individuals connected to the complaint will
    be made available to provide further evidence as required
    4. We confirm that the dispute has, where appropriate, been
    through a demonstrated genuine attempt of local resolution via
    the PCT DRP, (or other appropriate means) and that all other
    attempts at resolution have been completed.
    If you are appealing against the decision made by a PCT Dispute
    Resolution Process, you need to use the appeals form, to access
    the appeals form, please click here
    5. We confirm that no legal proceedings have commenced.
    6. We confirm that the dispute is not trivial, vexatious or an abuse
    of the SHAs procedures.
    7. We confirm that there is adequate time for the SHA to review
    the complaint appropriately. (Please note, if Alcatel2 or other
    time-limited pressures apply, there will be an opportunity for this
    to be highlighted in the form).

    We confirm that the above questions have been answered
    accurately and truthfully.




2
  “Alcatel” refers to the Alcatel mandatory standstill period. This relates to OGC advice
(following European Court of Justice rulings) on the need for a ten day standstill period
between advising tenderers of a contract award decision and entering into a contractually
binding agreement with the successful tenderer.

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Competition dispute resolution
Section A - Preliminary information

Please supply the following information:

Your business name: *
Your first name (please note you will be the
contact point throughout the process) *
Your last name: *
Your business address: *
Direct line telephone: *
Fax: *
E-mail address: *
Chief Executive name: *
Chief Executive address: *
Chief Executive e-mail address: *
A brief overview of your complaint. *
Please include, where possible:
   • background,
   • alleged infringement,
   • parties affected,
   • service(s) concerned,
   • concise chronology of events,
   • names of any other people or
       organisations outside of your
       organisation that we might contact to
       validate your claim
   • harm done to your business (if any).
       This should be specified and
       quantified in terms of financials and
       reputation.
   • remedy sought

If applicable, a brief explanation of the
nature of your business and its approximate
turnover
Details (including contact details and
personnel concerned) of the target(s) of the
complaint and the nature of their business:
Include their sector (if known, e.g. NHS,
Private Sector, Voluntary Sector etc): *
Details of any relevant contact with the
target of the complaint. Please include how
you have attempted to resolve this dispute
with them: *
Details of the relationship between your
organisation and the target of your complaint
(e.g. competitor / supplier etc).


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Section A - Preliminary information, continued



1. Are there any time-critical issues relating     Yes   No
to this complaint (e.g. is it within the Alcatel
period?) *

2. Does the subject of the complaint               Yes   No
potentially constitute a breach of law?




* denotes all mandatory fields




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Competition dispute resolution
Section B - PRCC Basis for complaint
Based on your responses to Stage 1 (assessment against the entry criteria),
you should be able to answer one or more of the following questions which
will help with our investigation. If you are unable to answer any of these
questions, it may be that the cause for complaint is not within the Principles
and Rules of Cooperation and Competition criteria, you are advised to seek
guidance from NHS London before you submit this form, should that be the
case.

For each of the PRCC rules you consider to have been breached by the
target, explain why you consider this rule to be breached, please give
examples specific actions or behaviours:

Principle 1
Commissioners should commission services from providers who are best
placed to deliver the needs of their patients and population



Why do you believe this principle has
been breached?
Can you refer to the actions or
behaviours that have resulted in your
cause for complaint


Can you refer to the specific rule that
has been broken regarding your
cause for complaint




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Principle 2
Providers and commissioners must cooperate to ensure that the patient
experience is of a seamless health services, regardless of organisational
boundaries, and to ensure service continuity and sustainability

Why do you believe this principle has
been breached?
Can you refer to the actions or
behaviours that have resulted in your
cause for complaint


Can you refer to the specific rule that
has been broken regarding your
cause for complaint




Principle 3
Commissioning and procurement should be transparent and non-
discriminatory

Why do you believe this principle has
been breached?
Can you refer to the actions or
behaviours that have resulted in your
cause for complaint


Can you refer to the specific rule that
has been broken regarding your
cause for complaint




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Principle 4
Commissioners and providers should foster patient choice and ensure
patients have accurate and reliable information to exercise more choice and
control over their healthcare

Why do you believe this principle has
been breached?
Can you refer to the actions or
behaviours that have resulted in your
cause for complaint


Can you refer to the specific rule that
has been broken regarding your
cause for complaint



Principle 5
Appropriate promotional activity is encouraged as long as it remains
consistent with patient’s best interests and the brand and reputation of the
NHS

Why do you believe this principle has
been breached?
Can you refer to the actions or
behaviours that have resulted in your
cause for complaint


Can you refer to the specific rule that
has been broken regarding your
cause for complaint




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Principle 6
Providers must not discriminate against patients and must promote equality

Why do you believe this principle has
been breached?
Can you refer to the actions or
behaviours that have resulted in your
cause for complaint


Can you refer to the specific rule that
has been broken regarding your
cause for complaint



Principle 7
Payment regimes must be transparent and fair

Why do you believe this principle has
been breached?
Can you refer to the actions or
behaviours that have resulted in your
cause for complaint


Can you refer to the specific rule that
has been broken regarding your
cause for complaint




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Principle 8
Financial intervention in the system must be transparent and fair

Why do you believe this principle has
been breached?
Can you refer to the actions or
behaviours that have resulted in your
cause for complaint


Can you refer to the specific rule that
has been broken regarding your
cause for complaint



Principle 9
Mergers, acquisitions, de-mergers and joint ventures are acceptable and
permissible when demonstrated to be in patient and taxpayers best interests
and there remains sufficient choice and competition to ensure high quality
standards of care and value for money

Why do you believe this principle has
been breached?
Can you refer to the actions or
behaviours that have resulted in your
cause for complaint


Can you refer to the specific rule that
has been broken regarding your
cause for complaint



Principle 10
Vertical integration is permissible when demonstrated to be in the patient and
taxpayers best interests and protects the primacy of the GP gatekeeper
function; and their remains sufficient choice and competition to ensure high
quality standards of care and value for money

Why do you believe this principle has
been breached?
Can you refer to the actions or
behaviours that have resulted in your
cause for complaint


Can you refer to the specific rule that

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has been broken regarding your
cause for complaint




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Competition dispute resolution
Section C - Other relevant information
Any supporting information should be provided with the complaint, for
example:

   • Copies of any relevant documentation (e.g. minutes of meetings, board
     papers etc) or communications (e.g. emails) involving the
     target/complainant as evidence
   • Copies of any relevant industry reports/consumer surveys
   • Details of any similar complaints/investigations/proceedings concerning
     the same or similar products/services (for example, an investigation by
     the European Commission).



Name of document 1

Description of document 1

Confirmation that document 1 has        Yes
been attached


Name of document 2

Description of document 2

Confirmation that document 2 has        Yes
been attached


Name of document 3

Description of document 3

Confirmation that document 3 has        Yes
been attached




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Section C - Other relevant information continued…

Name of document 4

Description of document 4

Confirmation that document 4 has     Yes
been attached


Name of document 5

Description of document 5

Confirmation that document 5 has     Yes
been attached


Name of document 6

Description of document 6

Confirmation that document 6 has     Yes
been attached


Name of document 7

Description of document 7

Confirmation that document 7 has     Yes
been attached

Please add more tables where appropriate




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Competition dispute resolution
Section D - Declaration
Please provide the following details:

Declaration by an officer of the company or by the complainant (as
applicable):

The information provided in this submission is correct and
complete to the best of my knowledge and belief. *
Submitted by (your name): *
Position in the Company: *
Date* (DD/MMM/YYYY)

Please send form to [named individual]




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Description: Resolution of Board of Director for Submitting Roc Forms document sample