Norwegian Merger Control 2023 published

Norwegian Merger Control 2023

An overview of the merger control regime in Norway

Oslo, February 2023

1. Overview of 2023

2. The Norwegian Merger Control System

3. BAHR – EU & Competition Law

Norwegian merger control in 2022 at a glance

A year of many firsts

• The Gulating Appeal Court overturned the first merger prohibition decision brought before the Norwegian courts

– Nettbil / Schibsted – cleared unconditionally by the Gulating Appeal Court

– The case is currently awaiting a ruling from the Supreme Court after appeal by the Norwegian Competition Authority (NCA)

• The Competition Appeal Tribunal (CAT) overturned the NCA in a merger case for the first time

– DNB / Sbanken unconditionally cleared after prohibition from the NCA

• Three concentrations approved with remedies

– Bewi / Jackon

• Competitors in the market for polystyrene boxes used for storage and cooling of fish (horizontal overlap)

• Cleared with structural remedy by sale of factories in certain local markets with overlap

– Hansa Borg / Royal Unibrew

• Competitors in the market for sale of cider and flavoured alcoholic beverages (horizontal overlap)

• The first time the NCA has cleared a merger on a quasi-structural remedy by termination of an agreement

– Nortura / Steinsland

• Nortura is a supplier of egg and poultry and Steinsland is a supplier of say-old laying hens (vertical relationships)

• Cleared with behavioural remedy on committing to delivery and agreements on non-discriminatory terms

• Two concentrations below thresholds called in for review (Axess Logistics/Auto Transport Service + SKion Water/Enwa)

NCA continues focus on select sectors

Markets and companies subject to additional disclosing requirements

• Certain companies are subject to additional disclosing requirements below merger filing thresholds when conducting M&A within “focus markets”

– Expanded disclosing requirements typically imposed in already investigated markets following cartel investigations and complex merger investigations

– Failure to inform the NCA has been sanctioned several times by NCA

– The NCA uses the information to decide if further investigation is warranted and may require a notification

• Trend: Gradual expansion of the types of transactions encompassed by the disclosing requirements

– Requirement on several companies now encompass also minority acquisitions

– Wording of the requirement tends to become broader, such as covering targets with “plans to offer” services towards users in Norway

Companies subject to expanded disclosing requirements as of January 2023

• Fuel: Uno-X Energi, St1 Norway, Certas Energy Norway and Circle K Norway

• Electricity: Statkraft, Eviny, Skagerak Energi, Agder Energi/Å Energi and Hafslund Eco Vannkraft

• Waste management: Norsk Gjenvinning

• Groceries: Norgesgruppen, Coop Norge, Rema 1000 and Bunnpris IK Lykke

• News: Amedia, Polaris and Schibsted

• Security systems: Verisure and Sector Alarm Group

• Laundry services: Nor Tekstil

• Gardening centres: Plantasjen Norge

• Concrete: Nordic Concrete Group, Heidelberg Cement Norway and Unicon

• Accounting systems: Visma

• Sports equipment: Sport Holding

• Classified ads: Schibsted

• EV charging networks: Mer Norway, Circle K Norge, Eviny Elektrifisering, Recharge and Tesla Norway

NCA continues focus on select sectors

Prioritized sectors going forward

Prioritised sectors, as set out in the NCA’s Strategy Plan, 2022 – 2027:

Grocery market

• Subject of public debate and scrutiny from NCA, Government and Parliament

• The three largest players have reporting requirements to the NCA for all concentrations

Digital markets

• NCA continues to prioritize enforcement within the digital economy in accordance with mandate from Ministry

• In particular, the NCA is concerned about killer acquisitions

Green industries

• NCA continues to focus on enforcement within new «green» industries

– Obligation to notify aquisitions of control and minority shareholdings for electric car charging operators implemented spring 2022

– Sustainability a criteria for general prioritization of cases

Outcome of 1007 notifications under the current merger control regime (2014 – 2022)

Average handling time (business days)

1 case closed in Phase I with remedies

96.2% closed in Phase I without conditions (969 cases)

3.6% Phase II-cases (36 cases)

1 case transferred to the European Commission

38.9% closed in Phase II with remedies (14 cases)

19.4% prohibited (7 cases)

8.3% withdrawn (3)

33.3% closed in Phase II without conditions (12 cases)

All notifications 13.5 days

Phase I clearances 10.8 days

Phase II clearances 67.5 days

Remedies and prohibitions

Source: kt.no, einnsyn.no, document access, BAHR Note: Five of the Phase I cases were withdrawn in Phase I

102.5 days

Most notifications are unconditionally cleared in phase I

1. Overview of 2023

2. The Norwegian Merger Control System

3. BAHR – EU & Competition Law

Long tradition of merger control in Norway

• National merger control regime since 1988

• Economic analysis always been an integrated part of the merger analysis

• Strict enforcement

– Yearly a number of prohibitions and conditional clearances

– Fines imposed for gun jumping and insufficient information

Competition authorities in Norway

Case review: The Norwegian Competition Authority

Administrative review: The Competition Appeal Tribunal (CAT)

Transactions without EU dimension

Reviews all merger notifications and has the power to authorise (with or without remedies) or prohibit concentrations

Appeals over the NCA’s merger decisions are reviewed by CAT

Judicial review: Gulating Court of Appeal

Decisions by the CAT in merger cases are subject to judicial review before the Court of Appeal in Bergen

Judicial review: Supreme court

Decisions by the Gulating Court of Appeal are subject to judicial review before the Supreme court

Transactions with EU dimension

Concentrations with an EU dimension under the EUMR excluded from the NCA’s jurisdiction

Turnover in Norway not relevant for the calculation of turnover thresholds under the EUMR

Transactions with EFTA dimension

Concentrations may under exceptional (theoretical) circumstances be subject to EFTA Surveillance Authorities jurisdiction

Mandatory notification if statutory thresholds exceeded

1 2 Applies to concentrations If turnover thresholds are met

Definition of concentrations harmonized with the EU:

• Mergers, acquisition of de jure or de facto control and full-function joint ventures

• Rights, agreements or contracts giving decisive influence over assets to which a market presence can clearly be attributed

• Combined turnover in Norway of all the undertakings concerned  NOK 1bn ( EUR 99 million / USD 103.9 million)*, and

• Turnover in Norway for each of at least two parties  NOK 100m ( EUR 9.9 million / USD 10.4 million)*

Definition of undertaking concerned harmonised with EUMR. Relevant turnover (not harmonised) = “sales revenues” as defined in the Norwegian accounting act and associated regulations

Foreign-to-foreign transactions covered if sales to or in Norway exceeds the turnover thresholds. The NCA has indicated that foreign-to-foreign transactions may escape mandatory notification if no effect

The NCA has the power to require notification of non-controlling shareholdings and concentrations falling below thresholds

Non-controlling shareholdings

No mandatory notification, but notification may be required by the NCA or submitted voluntarily Notification must be required by the NCA within three months after final agreement or completion of transaction (whatever occurs first)

The NCA has used this power twice – one time leading to conditions (reduction in ownership share)

Concentrations falling below thresholds

No mandatory notification, but may be required by the NCA or submitted voluntarily

NCA deadline for requiring notifications: three months after final agreement

The NCA actively seeking to uncover potential harmful transactions below thresholds

• Several market players have been required to inform the NCA of all transactions in selected markets, irrespective of thresholds

• Screening of markets and whistle-blower form on the NCA web site

10 requirements issued since the current notification thresholds were introduced in 2014

• Voluntary notifications are possible

Number of required notifications (below thresholds)

•

Timeline for NCA merger review

Prenotification

1-2 months in complex matters

• Longer if remedy discussions

Phase I

• 25 working days

• 35 wd if remedies proposed before day 20

Clearance, remedy decision, or

Phase II

Phase II

• 70 wd (from notification)

• Max 85 wd if remedies proposed late

• Automatic standstill until final decision or conclusion of investigations

• Phase II-deadlines not affected by a possible extension of phase I

Clearance, remedy decision, or S.O.

Parties’ comments to S.O.

• 15 working days

NCA Final assessment

• 15 WD

• Max 45 wd if remedies offered after SO

Clearance, remedy decision, or prohibition

• Maximum 100 working days from notification to final decision if no extensions – max 145 working days if all possible extensions

– Extensions if remedies proposed late in phase II or after statement of objections (S.O.)

• Clock-stop possible if parties do not respond to an RFI within time

• Automatic clearance if any NCA deadline passes without action

Referrals between the Commission and the NCA

Concentrations may be referred between the Commission and Norwegian competition authorities under the same basic principles as referrals to and from EU Member States, albeit with some variations

Pre-notification referrals

• The parties may request a referral to the Commission where at least three EU Member States are capable of reviewing the transaction

• Note that Norway as an EFTA State is not counted in this respect

• Norwegian authorities have no general veto power, and may in principle also initiate parallel proceedings

• The parties may request a referral from the Commission to the NCA by means of a Form RS

Post-notification referrals

• The NCA has no right to request referral to the Commission at its own initiative, but may adhere to requests from EU Member States

• 2020: The NCA joined the Danish Competition and Consumer Authority’s Article 22 request in M.9744 MasterCard/Nets

• 2021: The NCA joined the French Competition Authorities’ Article 22 request in M.10188 Ilumina/GRAIL

• Time limits for Norwegian merger review suspended when EU Member States request referral

• The Commission may refer cases to the NCA, and has done in several cases:

• M.2683 Aker/Kværner (II), M.4611 Egmont/Bonnier (books), M.6752 Orkla/Rieber and M.6982 Altor Fund III/Tryghedsgruppen/Elixia/ HFN Group (“SATS/Elixia”)

Harmonised SIEC-test

• Substantive test: Harmonised with the EU with SIEC-test

• Consumer welfare standard; only efficiencies with impact on pricing are relevant

• The substantive test was amended from 1 July 2016

– Previously, Norway applied a SLC/total welfare test

– No significant apparent changes in review intensity or number of interventions

“The NCA shall prohibit concentrations which would significantly impede effective competition, in particular as a result of the creation or strengthening of a dominant position”

Interventions/conditional clearances since 2015

V2015-1 TeliaSonera / Tele2 Norge & Network Norway

V2015-24 Coop Norge / ICA Norge

V2015-29 St1 Nordic / Smart Fuel (Shell retail Norway)

V2015-30 Orkla / Cederroth

V2015-31 Aleris Helse / Teres Medical Group

V2016-3 AT Skog / NEG Skog

V2016-5 Torghatten / Fjord 1

V2016-6 Umoe Restaurants / Dolly Dimple’s

V2017-19 Eimskip / Nor Lines

n/a Greencarrier et al / Nordic Port Services

V2018-19 St1 Norge / Statoil Fuel & Retail Marine

V2018-18 Vipps / BankAxept / BankID Norge

V2019-17 Sector Alarm / Nokas Small Systems & Nokas (minority acquisition)

consumer goods

stations

care products

hospitals

ferry services

restaurants and home

transport of frozen seafood

oils

services

services

n/a NorTekstil / Rent Nordvest Laundry services

V2019-22 Prosafe / Floatel International

V2019-23 Tieto / Evry IT services

accommodation services

V2020-31 Schibsted / Nettbil Online advertising of cars

V2021-07 Altia / Arcus

n/a Bonnier Books / Strawberry publishing Book publishing

V2021-13 DNB / Sbanken

V2022-4 Royal Unibrew / Hansa Borg

V2022-8 Nortura / Steinsland

V2022-10 Bewi / Jackon

* Pending before the Supreme Court

(de facto prohibition)

distribution

beverage distribution

and poultry production

material

prohibition, partly structural remedy

in phase II

remedy (phase I)

remedy

in phase II

remedy

remedy

remedy

Prohibitions and conditional clearances: 2014–2022

3 Phase II clearance decisions after SO since 2014

• Norgesgruppen ASA – Tiger AS (2015)

– Convenience retail

– Closed after 105 working days

• Telia Company AB – Phonero AS (2016)

– Mobile telephone services

– Closed after 104 working days

• Gjelsten Holding AS / O.N. Sunde A/S – Gresvig Retail Group and subsidiaries (2020)

– Sports retailing

– Closed after 107 working days

Procedure

No formal deadline for filing

• Standstill obligation for all concentrations subject to mandatory notification

• Prenotification dialogue or draft notification not required but recommended in more complex matters (and expected by the NCA)

• Prenotification may be necessary if seeking phase I remedy decision

Phase I

Within 25 working days, the NCA must approve the transaction or decide to continue the investigation (“Phase II decision”)

• If the parties propose remedies within the first 20 working days after the notification the period is extended to 35 working days

• A decision to continue the investigation is normally short and briefly indicates the NCA’s concerns and theories of harm

• No formal decision if the NCA authorises a concentration unconditionally in Phase I, but confirmation by email

Phase II: Before statement of objections

Phase II: After statement of objections

Within 70 working days from reception of complete notification, the NCA must issue its statement of objections or clear the case

• If the parties propose commitments later than 55 working days after notification, Phase II is extended correspondingly

• Unconditional phase II clearance decisions are normally brief, only shortly pointing to key arguments for closing of the inquiry

• Parties have 15 working days to submit comments

• NCA must issue final decision (clearance, prohibition or acceptance of remedies) within 15 working days of the reception of the parties’ comments

• 15 working days extension if the parties propose remedies after the draft prohibition decision

• Additional 15 working days extension if parties request or approves a request from the NCA

Automatic standstill until final decision

Automatic standstill for all concentration subject to mandatory notification until final decision

Standstill also for notifications required by the NCA or submitted voluntary

• From the moment NCA require notification or the notification is submitted voluntarily

• If the transaction has been completed when standstill comes to force, the NCA will typically indicate that any further implementation must be halted

• Though the legal basis may be questioned after C-633/16 Ernst & Young

Exemptions:

• The NCA may grant derogation from standstill obligation:

• Derogations only granted if significant negative impact on the parties or society as a whole can be established

• Derogation may be granted for “rescue operations” (e.g. risk of bankruptcy) in cases without substantial issues

• The NCA appears to prefer a swift approval rather than derogation

• Partial exemption for public bids and series of transactions in publicly-traded securities (similar to EUMR Art.7(2))

The notifying party/-ies can offer remedies

The notifying party/-ies have the sole responsibility for offering remedies

• Both behavioural and structural remedies however the NCA has historically had a preference for structural remedies

• Remedies may also include the appointment of a trustee

• Normally a dialogue between the notifying parties and the NCA prior to offer of remedies, but the NCA guidance is often brief

The NCA may issue a decision including remedies offered by the parties without full review of possible anti-competitive effects resulting from the concentration

• In practice the NCA is not ready to hand down a remedy decision before all potential theories of harm have been investigated

• The proposed remedy must remove all identified concerns

• A decision accepting remedies offered by the parties may be handed down without prior notification that the NCA intends to adopt such a decision

• Limits the NCA’s obligation to conduct a full investigation, e.g. with respect to whether the remedy goes further than strictly necessary

• Decision to clear the concentration subject to remedies may be adopted in Phase I – so far only one Phase I remedy decision has been made (Tieto/Evry)

Pre-notification contacts are typically less comprehensive in Norway compared to many other jurisdictions

• No “adequacy test” of draft notification required before formal notification, but draft notification often submitted and reviewed in more complex matters

• The NCA may declare the notification incomplete within 15 working days of reception

In more complex cases pre-notification contacts more regular

• Can be important in order to achieve Phase I clearance in “semi-complex” matters

• Also in potential Phase I remedy cases

• In less complex cases (incl. simplified notifications) simple pre-notification contact recommended and appreciated by the NCA as a courtesy, but not necessary

• Often sufficient to give a courtesy pre-warning that a notification will be submitted

Information provided during pre-notification not subject to public disclosure until formal notification, unless the concentration is publicly known

Pre-notification contacts less comprehensive than in many other jurisdictions, but increasingly more regular

Information required in notifications

• No strict notification form in Norway, but minimum content requirements are regulated in the Competition Act

• Need to identify confidential information

– Including a reasoned opinion on why the identified information is considered confidential

– The notification will not be declared complete before such information is submitted

• The NCA may declare the notification incomplete within 15 working days from reception

Minimum content requirements:

1. Description of undertakings concerned and their business areas and the nature of the concentration

2. Name of each party’s five most important competitors, customers and suppliers in all markets with horizontal overlap (no market share threshold)

3. For horizontally and vertically affected markets, describe:

i. Market structure

ii. The most important competitors, customers and suppliers in the affected markets

iii. Barriers to entry

iv. Horizontally affected: Combined market share > 20%

v. Vertically affected: Market share > 30% in both vertically related markets

4. A short description of vertically related markets where the market share exceeds 30% in only one of the related markets

5. Description of any efficiency gains

6. Information on whether the concentration is subject to mandatory notification in any other jurisdictions

7. The latest version of the agreement between the parties to the concentration including annexes

8. Annual reports and annual accounts of the undertakings concerned

9. For joint ventures: Information on whether a parent continue activity in the same market as the joint venture or any vertically related markets

Internal documents not required, but normally requested in more complex matters

Simplified notification for non-complex cases

Short form notification for certain concentrations:

• Creation of joint ventures when the turnover of the joint venture is below NOK 100m in Norway and assets transferred to the joint venture is valued below NOK 100m;

• Dissolution of joint ventures (from joint to sole control);

• Horizontal mergers where joint market share  20 %; or

• Vertical mergers where joint and individual market shares  30 %

Short form notification must include the following information

• Identity of the parties

• Description of the transaction

• A statement describing why the conditions for simplified procedure is fulfilled

• List of the five most important customers, competitors and suppliers in horizontal overlap markets

• Annual reports (if not publically available)

• In case of creation of joint ventures, an overview of markets where parents will remain active in the same market as the joint venture or in any vertically related or neighbouring markets

The NCA must notify within 10 working days if conditions for simplified notification is not met

The NCA may order a standard notification within 15 working days after reception of a simplified notification

• Deadlines suspended from order of notification until reception of (complete) standard notification

• Rare; has happened twice since 2014

Publicity and access to the file

• The key facts of the notification is published on the NCA’s website, providing the names of the parties, relevant sector and date of reception

• The parties and interested third parties have access to file during the NCA’s review of the case

• Exceptions include: (i) business secrets, (ii) the NCA’s internal documents, except for summaries of facts, e.g. minutes of meetings, and (iii) correspondence between Norwegian and foreign authorities

• Access is not given to pre-notification documents before the concentration is public or notified

• The parties must submit a draft non-confidential version of notifications and remedy proposals when these are submitted

• The NCA may presume that the parties do not oppose public access to information that is not clearly marked as confidential

• Reasons for why information should be considered as confidential must be given for every instance of suggested redaction

• Since 2022, NCA regularly publishes a non-confidential version of the notification directly at the NCAs webpages

Administrative review by the Competition Appeal Tribunal

• Appellate body from 1 April 2017 is the Competition Appeal Tribunal

– Competition Appeal Tribunal has thus far reviewed two appealed merger decisions

• Full review of all aspects of the case

– The Tribunal may review the facts, the discretional assessment and application of law in cases that are appealed

– Not limited by the issues raised in the appeal or the decision

• Possible outcomes

– Prohibition decisions by the NCA: The Tribunal is not bound by initial NCA decision and may issue a new decision

• The Tribunal may confirm the NCA decision, clear the transaction or issue a conditional clearance

– Conditional clearance by the NCA: The Tribunal may only confirm or annul the NCAs decision

• Annulment when the Tribunal finds that the conditions for intervention are not fulfilled: Appeal decision is final

• Annulment due to other reasons (e.g. procedural errors or remedies considered inadequate): NCA must adopt new decision or issue a draft prohibition decision within 45 working days

• Competition Appeal Tribunal decisions are subject to judicial review by the Gulating Appeal Court in Bergen

– The Gulating Appeal Court recently reviewed it’s first merger decision (Schibsted / Nettbil)

Time line for administrative review by the Competition Appeal Tribunal

decision

Appeal

Parties: Possible CAT Hearing

(1) Prolonged accordingly if parties propose commitments later than 35 working days after appeal decision

(2) Clearance decisions may be “full” or subject to (new) remedies as offered by the notifying party/-ies

(3) If remedies are offered by the parties after draft prohibition decision

• In cases where the NCA clears a transaction subject to remedies, the Appeal Tribunal may only:

− Confirm the NCA decision

Clear the transaction unconditionally, or

Return the transaction to the NCA for a renewed treatment

• Prohibition decision: The Appeal Tribunal is not bound by the initial decision and may make new decision or return the case to the NCA for renewed treatment

1. Overview of 2023

2. The Norwegian Merger Control System

3. BAHR – EU & Competition Law

BAHR takes a holistic approach

Pre-assessment National International

We take pride in providing an early advice and structuring the process to fit your business needs

• Early screening of where filing is required, likelihood of clearance and potential remedies

• We structure the process on filing strategy, timing issues and handling of information sharing in close interaction with our M&A department

• Economics integrated in all phases; from preliminary assessments and throughout the filing process –including design of remedies

– BAHR is the only Norwegian law firm with an in-house competition economist

We have extensive experience in handling both complex and uncomplicated cases before the NCA

• Expedient handling of uncomplicated cases

• Extensive experience with complex cases:

– BAHR has handled 2 of 3 phase II clearance decisions issued after SO since 2014

– BAHR has handled the only merger case that has been overturned at the CAT

• Experience in handling extensive information requests

We are well placed to efficiently handle your multijurisdictional merger filings in close cooperation with our extensive international network

• BAHR provides a one-stop-shop for multijurisdictional filings

– BAHR has handled a large number of cases before foreign competition authorities in cooperation with our extensive international network – we frequently interact with law firms in Europe, South-America, the US and Asia

• BAHR has handled cases before the European Commission

BAHR selected highlights in 2022

• BAHR handled the filing of Norway’s leading bank DNB’s acquisition of rival Sbanken

• The acquisition strengthened DNB’s position in important markets such as mortgages and savings

• Prohibited by the NCA, cleared unconditionally by the CAT

• First ever clearance by CAT following a NCA prohibition

• BAHR handled the filing for SalMar’s acquisition of NTS before the European Commission and the NCA, and coordinated the filing to the Icelandic Competition Authority

• The transaction created the second largest salmon farming company in the world

• BAHR secured clearance with remedies in Phase I (EU), and unconditional clearance in Norway and Iceland

• BAHR handled the filing of Hafslund’s (a leading Norwegian renewable electricity supplier owned by Oslo Municipality) acquisition of Fortum Oslo Varme AS

• The transaction created a leading player within the market for waste incineration services

• BAHR secured unconditional clearance in Phase I

• BAHR represented Noble Corporation for the NCA filing of the integration of two leading offshore drilling companies Maersk Drilling and Noble Corporation

• The transaction created a leading drilling company in the North Sea

• BAHR secured unconditional clearance in phase I; in the UK, the merger was cleared in phase I with remedies

• BAHR represents Aker Solutions in the creation of a Joint Venture combining the subsea business of Aker Solutions and SLB. The JV will be controlled by SLB

• The transaction involves merger filings a number of jurisdictions

• BAHR handled the filing towards the NCA and coordinates the worldwide notification process

• BAHR handled the filing of the merger between Aker BP’s and Lundin’s hydrocarbon exploration & production business

• The merger created the second largest oil and gas producer on the Norwegian Continental Shelf

• BAHR secured unconditional clearance in Phase I

BAHR’s EU & Competition Team

"The team provides sharp analysis and is highly productive," enthuses a client further, highlighting the "complementary legal and economic analytical skills”.

Reflecting on their cooperation, one client lauds: "The team approaches the competition field from all angles with creativity and is hard-working and gets the work done."

Chambers Europe 2022

Consistent Top Ratings

Some Examples

Top ratings in all the major national and international league tables

– Top ranked Band 1 in ten categories and Band 2 in five categories in Chambers Europe 2022 and 2021

– Top ranked Band 1 in six categories and Band 2 in one category in Chambers Global 2022 and 2021

– Top tier in sixteen categories in the 2022 edition of Legal 500

– Top ranked as “Elite firm” in the category ‘Competition law’ in the 2021 and 2020 edition of GCR 100

– Firm of the Year (Norway), Benchmark Litigation Europe Awards 2021and 2019

– Dispute Resolution Firm of the Year (Norway), Benchmark Litigation Europe Awards 2020

– Patent Litigation Firm of the Year (Norway), Global IP Awards 2020, 2019 and 2018

– Firm of the Year (Norway Contentious), Managing Intellectual Property EMEA Awards 2019

– Most Innovative Law Firm of the Year Award for Norway, IFLR European Awards 2019 and 2017

– Norway Law firm of the Year, Chambers Europe Awards 2018

– Norway Legal Adviser of the Year, Mergermarket European M&A Awards 2018

BAHR’s EU & Competition team: Consistent Tier 1 rankings

• Both Helge Stemshaug and Beret Sundet are ranked among three tier 1 Competition / Antitrust lawyers in Norway by Chambers

• Helge Stemshaug named as Thought Leader 2023 by Who’s Who Legal – Competition

• Beret Sundet ranked in “Hall of fame” by Legal500 – EU and Competition

Contact details

Helge Stemshaug Partner

T +47 928 81 396

E hst@bahr.no

“As one of Norway's top experts Helge Stemshaug is well placed to handle a variety of competition law mandates ranging from merger control to large-scale cartel investigations.”

Beret Sundet

Partner

Beret Sundet

Partner

T +47 928 81 385

E bsu@bahr.no

T +47 928 81 385

E bsu@bahr.no

“Beret Sundet remains a highly appreciated expert in the Norwegian competition law world, often handling merger control filings and antitrust compliance regarding M&A transactions as well as joint venture agreements.”

Arne Torsten Andersen Partner

T +47 971 47 338

E ata@bahr.no

"He is a good strategic adviser and is capable of considering the client’s legal position and is good at understanding the client's needs."

Chambers Europe 2022

Chambers Europe 2022

Chambers Europe 2022