The Hellenic Competition Commission (“HCC”) carried out a surprise on-site inspection on 4 November 2026 at businesses operating in the supply, processing, packaging and marketing of table olives, as well as at a related association of undertakings. The HCC is investigating, as part of an ex officio inquiry, a possible agreement or concerted practice between competitors and/or a decision by an association of undertakings, in particular to fix the purchase price of products and other terms of trade, in breach of Article 1 of Law 3959/2011 and/or Article 101 of the TFEU.
Inspections are carried out at businesses and associations of undertakings from which evidence of anti-competitive practices in the market under investigation may be gathered. They do not prejudge whether the businesses or associations have engaged in anti-competitive conduct, nor the outcome of the investigation.
HCC action in the agri-food sector
The agri-food sector is a priority for the HCC, particularly at a time of inflationary pressures, a rising cost of living for Greek consumers, successive crises in global supply chains and geopolitical instability, with climate change also a stark reality.
The HCC uses all the tools at its disposal to investigate competitive conditions along the agri-food supply chain and to intervene in a targeted and effective manner where distortions of competition are identified. Its work includes intervention tools of varying scope and intensity:
- Enforcing competition law by investigating anti-competitive practices in the market and penalising offenders, as well as reviewing mergers before they take place;
- Promoting competition policies in the Greek economy and society; and
- Conducting research through the systematic and targeted mapping of markets and sector inquiries across the economy.
The ex officio investigation by the HCC’s Directorate-General for Competition (DGC) into the table olive sector falls into the first category of action, the relevant announcement said.
For details of the HCC’s investigations in the agri-food sector, see here.
Legal framework
The HCC, as guardian of the proper functioning of the free market, is responsible for enforcing competition rules under Law 3959/2011 and Articles 101 and 102 of the TFEU.
- Article 1 of Law 3959/2011 and Article 101 of the TFEU prohibit agreements between businesses—including agreements, decisions by associations of undertakings and concerted practices—that have as their object or effect the restriction of competition.
- Article 1A of Law 3959/2011 prohibits unilateral practices that amount to an invitation to engage in a prohibited agreement, as well as the disclosure to competitors of future pricing intentions for products and services.
- Article 2 of Law 3959/2011 and Article 102 of the TFEU prohibit the abuse of a dominant market position by businesses.
The HCC says that, within its remit, it will intervene as an immediate priority wherever necessary and examine any relevant case that comes to its attention, whether through a complaint, a leniency application, anonymous information submitted via its secure digital whistleblowing platform or other means. It will impose the strictest administrative penalties on businesses found to have engaged in anti-competitive practices under Law 3959/2011 and Articles 101 and 102 of the TFEU.
The HCC’s leniency programme
Finding that a business has participated in cartel-type agreements—that is, secret agreements between competitors to fix prices or quantities, allocate customers or market shares, or rig bids—may result in substantial fines imposed by the HCC, criminal penalties for the individuals responsible, and the exclusion of the businesses involved from public tenders and concession contracts for three (3) years from the date the decision is issued.
Joining the HCC’s leniency programme offers significant benefits to businesses, associations of undertakings and individuals involved in such agreements, including:
- Full or partial immunity from administrative fines, or a reduction in fines;
- Immunity from criminal liability or a reduced penalty for the individuals responsible;
- Full exemption of the business from administrative sanctions of any kind; and
- Protection from exclusion from public tenders or concession contracts.