The grocery retail market: is antitrust efficiently handling this market?

73 Pages·2013·0.64 MB·English

International Report Question A:

“The grocery retail market: is antitrust efficiently handling this
market?” (merger, restrictive practices, abuse of dominant position)
Frederic Jenny1

This report synthesizes the seventeen national reports answering the questionnaire on the
grocery retail sector2.
At the outset a caveat is necessary. A large proportion of respondents to this survey come
from countries which are Member States of the European Union and share the same
(European) legal system. At the same time, and even though non-European countries such as
the United States, Japan or Australia responded to the questionnaire, some major countries
with a long experience in competition law and competition policy did not provide a national
report. It should thus be clear that, to a certain extent, the observations and conclusions in this
report are influenced by the particular set of countries which have responded to the LIDC
questionnaire. We are, however, confident that the examination of the 14 countries which
have contributed allows us to come to some robust conclusions.
Before starting our analysis with an examination of the structure of the grocery retail sector,
five general observations are in order.
First, laws that apply to the grocery retail sector are to a large extent the same laws that apply
to the retail sector in general. Those laws are partly laws that apply to all economic sectors
(such as competition law) partly laws which are specific to the retail sector (such as the laws
establishing the conditions under which a large scale retail store can be opened) and, more
rarely, some laws or regulations which are specific to the grocery retail sector (such as some
consumer protection laws applying to the sale of fresh products). Whenever possible, we have
tried to identify either what was specific to the grocery retail sector or how general principles
or laws applicable to the whole retail sector were applied specifically in the grocery retail
sector.
Second, while most countries which provided a report are countries which have a civil or
continental system of law, this is not the case for Australia and the United Kingdom. As we
shall see, the style of competition law enforcement for the grocery retail sector in those
countries is markedly different from what it is in other countries ( in particular, they rely more
on self-regulation than the other countries in the sample).
Third, a study of competition issues in the grocery retail sector requires consideration of the
relationship between retailers and their suppliers, whether they are manufacturers of prepared

1
 Professor
 of
 law
 and
 economics

 at
 ESSEC
 Business
 School
 (
 Paris),
 Visiting
 professor
 of
 law
 University
 College

London

2
 The
 seventeen
 reports
 surveyed
 are
 the
 reports
 from
 :
 Australia,
 Austria,
 Belgium,
 Bulgaria,
 Estonia,
 Finland,

France,
 Germany,
 Hungary
 ,Italy,
 Japan,
 Netherlands,
 Romania,
 Sweden,
 Ukraine,
 United
 Kingdom,
 United

States.

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food or intermediaries trading in agricultural products. As we shall see, the relationship
between the intermediaries and the suppliers is also of interest to understand their downward
relationship with grocery retailers. Thus most of the contributions extensively analyze the
vertical chain which start with farmers and ends with the retailers and we will report on the
sometimes complex relationships between the upstream level and the downstream level along
the vertical chain to shape competition on the final market for grocery goods.
Fourth, the word grocery may be imprecise since, particularly in the modern retail sector,
grocery stores have diversified their offerings and sell a wide variety of fresh or transformed
products, some of which are food products and others are non-food products. Most of the
contributions focus on the offering of products derived from agriculture, whether transformed
or not, in retail groceries. Indeed it seems that it is in this part of the market that the
competition problems are the most complex. This report also focuses on the foodstuff part of
the grocery retail sector.
Fifth, the countries which are being investigated have different histories, different levels of
economic developments, different cultures and different legal systems. A number of the
observations that one can make when comparing the situation of competition and competition
law enforcement in the grocery retail markets of these countries are grounded in those
differences.
Economic Background
In our sample of countries the concentration of the grocery retail sector varies widely from
one country to the next. One can distinguish three groups of countries.
First, countries where the retail grocery sector is very highly concentrated: this group includes
Australia ( C =80%), the Netherlands ( C =55%), Austria ( C =87%), Finland ( C =80%) and
2 2 3 2
Belgium ( C =75%). The Australian report suggests that large retailers have buying power
3
over food processors but that their buying power over farmers is less certain because farmers
have an alternative in export markets. Thus, it appears that the idea according to which more
concentration usually means less intense competition may not always hold in the grocery
retail sector.
A second group of countries exhibit medium to low concentration in the grocery retail sector.
In this group one finds Germany ( C =85%), Sweden ( C =80%), Estonia ( C =60%), France
4 4 3
( C =80%), the United Kingdom ( C =85% and C =66%) and Italy where the modern
6 8 4
distribution model accounted for about 70−72% of food product sales in recent years. In other
words, the “natural” shift in food product sales from small traditional shops and other market
entities to large-scale retail outlets seems to have stopped at the levels noted above. As for
the Netherlands, the report from Germany mentions strong price competition. The Swedish
report suggests that because food processors in Sweden are fairly concentrated the buying
power of retailers and the selling power of food processors are fairly balanced. Finally the
report concerning the United Kingdom suggests that farmers’ unions are able to exert
industrial and political pressure on processors and retailers (thus limiting their buying
power).
In a third group of countries, concentration of the retail sector appears to be low or very
low. This group includes the United States where the top 20 retailers account for 63.7%
of the market and the top four retailers hold 37% of the market. According to recent
2
research “The longer term trend shows an increasing concentration of sales among the
Nation's largest grocery retailers.” (…) “One contributing factor to such increases over
the past decade has been the rapid growth of Wal-Mart Supercenters. Their food and
nonfood grocery sales amounted to an estimated $109.4 billion in 2011, making it the
largest U.S. retailer of grocery products. In comparison, second-place Kroger, the
largest traditional grocery retailer, had sales of $71.1 billion in 2011.” There is concern
that Wal-Mart will or already has gained effective monopolies in poor, rural
communities and has exhibited monopsony power in many products.
A 2006 study found the entry of a Wal-Mart into a local market leads to significantly
increased grocery retail concentration; state and local studies generally lead to similar
conclusions. It is noted that the impact of Wal-Mart Supercenters on concentration
tends to occur in more rural, lower income communities. In counterpoint, however,
Wal-Mart frequently offers lower cost groceries than competitors and forces many
competitors to lower prices in response. By offering lower prices, Wal-Mart generally
escapes US antitrust notice under the prevailing US theory of consumer welfare.
Nonetheless, the long-tail of discount retail concentration through Wal-Mart’s growth is
as yet unknown. The author of the United States national report also suggest that Wall-
Mart’s power will be offset in the long run by the entrance of major players such as
Amazon that do not conform to traditional geographic markets and can and do provide
a platform for small batch and niche products but acknowledges that the speed of such
change in the communities most dominated by Wal-Mart today may be slow, as
infrastructure like high-speed wireless and home amenities such as computers lag.
Additionally, they note that as firms like Wal-Mart and Amazon create infrastructure
that retail market begins to rely on, possible duopoly, duopsony, and essential facility
concerns have the potential to develop.
This group of countries with low concentration in the grocery retail sector also includes
Hungary (C =40%), Bulgaria, Romania and Ukraine. In those countries (particularly in the
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latter three), the development of modern retail is relatively recent since this form of retail
appeared only after the countries moved to a market economy in the 1990s and a strong
attachment to traditional forms of small scale retail still seems to exist in at least some of
these countries. For example in Romania, 60 percent of Romanians prefer to buy their
groceries from a traditional trade unit (corner or neighborhood shop) and in Bulgaria , in
2010, about 60-70 % of all grocery sales were channeled through traditional retail
establishments.
It is more difficult to categorize intermediaries and food processors. Not only does the
situation vary from one country to another, but the situation varies from one grocery product
to another within the same country. Furthermore, not all reports provide details about the
intermediaries or the processors of food products.
The report for Australia, where concentration at the retail level is high, mentions that modern
grocery retail chains, which tend to be vertically integrated in the sense that large scale
retailers are also wholesalers, have a strong bargaining power vis-à-vis food processors since
their suppliers have almost no option to sell to anyone else.
The situation seems to be different in Finland and Sweden, also countries where there is a
high level of concentration at the retail level, but where we are told that certain food
processing markets are relatively concentrated with only a few major players. Thus in those
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two countries it would seem that the buying power of large grocery retailers is partly
compensated by the market power on the selling side of food processors.
In the United States, while grocery consolidation is rising, it is still low at the national
level, and is not likely to be an antitrust concern at the national level in the near future.
But greater antitrust concerns are generated by rising concentration at the food
processor and manufacturing level in some markets. As processors focus on new
technology, economies of scale, and low energy costs as key drivers of economic viability
they have consolidated heavily. Now there is a top four concentration measure of 50-
80% in most processing markets.
In Italy, no generalization can be made about industrial production: some sectors are
unconcentrated, but others have undergone an ever increasing concentration projects in recent
years. The report from Italy suggests that the two strategic variables which explain the
concentration or the lack thereof at the manufacturing level: the importance of the static type
economies of scale and the degree of differentiation of offerings.
In Belgium and Bulgaria, it seems that the dominant feature of the food processing industry is
the importance of multinational firms (even if the Bulgaria report also mentions the existence
of a local, fragmented food processing industry).
By contrast Austria and Germany appear to be countries where the food processing industry
is mostly composed of small and medium-sized suppliers with a narrow national or even
regional focus and often only minor market relevance. In those two countries the buying
power of retail (or discount) chains does not seem to be matched by the exercise of market
power on the selling side by food processors.
The only information we have about the United Kingdom is that the situation of processing
varies quite a bit depending on which grocery product one considers.
If one moves now from processing to agricultural production, the situation can again be
divided into three types of situations:
In countries such as Bulgaria, Austria, Italy, Romania and Finland the agricultural sector is
extremely fragmented. It is interesting to note that two of these five countries (Austria and
Finland) are countries where the level of grocery retail concentration is high. As we saw
previously, there is some concentration at the food processing level in Finland and Italy, but
this does not seem to be the case in Austria where grocery retail chains are likely to have
unchallenged buying power.
In countries such as the United Kingdom, the Netherlands, or Sweden, even though
agricultural production is atomistic, farmers sell through associations or cooperatives and thus
have some market power. The United Kingdom report describes a situation where farmers are
able to exert considerable political and business pressure on the downstream food processors,
wholesalers and on the retail sector.
Finally the situation in Germany seems to be in a state of flux with a steady decline of the
total number of agricultural production entities and a growing number of large entities in
primary production.
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The economic assessment of the structure of grocery retail, food processors and agricultural
production suggests that different competition problems will be prevalent in different
countries. In some countries buyer power will be confronted with seller power and there will
be a balanced confrontation between the two, sometimes in spite of a high level of grocery
retail concentration (for example in Sweden, the United Kingdom and Australia). In other
countries (such as, for example, Germany buyer power will prevail and public policy will be
focused on ensuring that this power is not used unfairly or anti-competitively. In a third type
of country (such as Bulgaria, Romania, Ukraine), both retailers and suppliers will have an
atomistic structure, at least at the general level, and the main issue will be the abuse of
dominance of those few retailers having a large market share at the local level.
But in order to better understand the competition issues in the grocery retail sector, one must
have a close look at the legal and regulatory environments OF RETAIL GROCERY :

Legal Background
In
 many
 countries
 a
 large
 number
 of
 laws
 and
 regulations
 apply
 to
 the
 retail
 sector.
 The
 goals
 of

those
 laws
 are
 to
 promote
 competition
 or
 to
 ensure
 fairness
 in
 exchanges
 or
 to
 regulate
 certain

aspects
 of
 the
 retail
 trade
 for
 socio-­‐political
 reasons.
 Whereas
 those
 goals
 might
 seem
 at
 first
 sight
 to

be
 complementary,
 they
 are
 often
 contradictory.

The situation in the United States is in sharp contrast with that of the other respondents.
The US has both less competition-specific regulation and less overall regulation when
compared with many European countries. To some extent the US approach is due to an
established pillar of its national constitutional law, a doctrine known as the Dormant (or
negative) Commerce Clause that, with a few exceptions, prevents states and
municipalities from responding to local merchants’ political pressure to erect
discriminatory and protectionist regulatory barriers against interstate (or foreign)
enterprises. In most industries, only Congress may create regulations that restrict trade
and investment.

Core provisions
Competition law

In most countries there is no specific competition regulation which applies to the grocery
retail sector which is subject to the general provisions of the competition law.
For example, in the United States, the grocery sector is covered by the Sherman
Antitrust Act, the Federal Trade Commission Act, and the Clayton Antitrust Act. The
industry is also subject to the Robinson-Patman Act, which was an amendment to the
Clayton Act, though Federal enforcement under the act is largely dormant and private
enforcement is dwindling. There are no sector-specific competition laws or exemptions
for the grocery retail market in the US.
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In some countries (such as, for example Austria, Bulgaria, Estonia, Hungary, Ukraine) the
competition law includes not only a prohibition of anti-competitive practices or transactions,
which might lead to the elimination, prevention, limitation or restriction of competition but
also a ban on unfair competition.
In most other countries the competition law and the law against unfair trade practices are
separate laws which both apply to the grocery retail sector. This is, for example, the case in
most members states of the European Union where national competition laws are usually
modeled on European competition law and apply concurrently with it.
The report from Italy states that the competition authority is in charge of the enforcement of
the Regulations to protect competition and the market, which is the general competition law
and applies to the grocery retail sector. With respect to the food sector, competition
regulations are aimed at ensuring that competition is fair (for example, encouraging restraint
in price increases, more competition on the markets and the access of new players, etc.).
Typically, national competition laws will prohibit horizontal and vertical agreements and
concerted practices which have as their object or effect the restriction of competition (such as
cartels or exclusive dealing), the abuse of a dominant position or the misuse of market power
such as exclusionary practices whereby a firm with market power or a dominant situation
eliminates competition) and anticompetitive mergers.
Several forms of conduct particularly relevant to the grocery sector such as cartels (price
fixing, market and customer allocation), primary boycotts, third line forcing or minimum
resale price maintenance are in certain countries subject to per se prohibitions.
In a few cases, the national competition law includes provisions which are specific to the
retail sector. This is, for example, the case in Germany. Section 20 (4) of the German Act
against Restraints of Competition (ARC) explicitly prohibits undertakings with superior
market power to abuse their market position by selling goods or services below cost price
without an objective justification. However, one should note that in the wake of a
controversial decision by the Federal Cartel Office on the pricing policy of a retailer, the
Upper Regional Court of Düsseldorf rejected the approach taken by Federal Cartel Office to
calculate the cost price. In light of this decision the prohibition to sell below cost price is
widely seen as of very limited scope. Further enforcement action in this area is unlikely as it
is deemed too complex to prove a sale below cost, given the extensive number of discounts
and conditions agreed upon between retailers and suppliers.
Occasionally, competition laws have been amended to better deal with concerns raised
primarily in the grocery sector.
Thus, for example, in 2007 Australia introduced into its competition law a specific
prohibition against predatory pricing which applies when a company with substantial market
share supplies, or offers to supply, goods or services for a sustained period at a below-cost
price for a prohibited purpose. The adoption of this provision was driven largely by concerns
about low cost pricing in the grocery market destroying small business.
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In some countries, even though there are no provisions specific to the retail sector in the
competition law, the government is considering the introduction of such a provision. For
example, in Finland a recently adopted section of the Competition Act stipulates that an
undertaking, whose market share is 30 % or more of the daily consumer goods retail
market, is considered to hold a dominant market position. When calculating the market share
of the grocery retailer, the total retail operations of all the undertakings belonging to a certain
retailer group would be taken into account.
Exemptions from competition law prohibitions
Different types of exemptions from competition laws can be found for the retail sector or
some parts of the grocery business. First, in a number of countries (in particular European
countries and Australia) there is an exemption for anticompetitive practices (for example
anticompetitive agreements) which contribute to economic progress or have public benefits.
Such exemptions are sparingly given, however. Second, in other countries where there is no
formal exemption groupings of small suppliers will get an exemption from competition law
for otherwise prohibited practices on public interest grounds. Third, some countries (again
certain European countries) have a de minimis exemption either resulting from European
competition law or unrelated (in which case they only apply to domestic practices which have
no effect on interstate trade). Fourth, a number of countries exempt, in part or in whole,
agricultural producers groupings from competition law (for example cooperatives in Japan).
Fifth, a smaller number of countries have (or had) block exemptions for voluntary chains of
small retailers.
Exemptions from competition law for agricultural groupings
In several countries specific anticompetitive practices may be exempted on the basis of their
contribution to economic progress or on public interest grounds. Those general rules apply to
the grocery sector.
For example, in the United States, farming cooperatives have limited immunity from
antitrust scrutiny by the 1922 Caper-Volstead Act.
In Australia, approval to engage in an anticompetitive conduct may be granted by the ACCC
(or, in the case of a merger, the Australian Competition Tribunal), where it can be
demonstrated that there is a likely public benefit that will outweigh any likely anticompetitive
detriment. In some cases, supermarkets have been permitted to agree on fees to charge for
plastic bags on the basis that there is a public benefit associated with reducing landfill waste.
In Australia, the exemptions take one of two forms: an ‘authorisation’ or a ‘notification’ of
the relevant conduct. Authorization provides a mechanism by which a party proposing to
engage in conduct that will or may contravene the competition law provisions can receive
immunity, on public benefit grounds, against action under the Act. It is available only in
relation to proposed conduct; there is no ability to authorize conduct that has already
occurred. It is also provided on a case by case basis; there is no facility for ‘block’
authorization of certain forms of conduct. The precise public benefit test varies slightly
depending on the conduct involved, but in practice the tests will be applied in a similar way.
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For cartels, anti-competitive agreements and exclusive dealing (other than third line forcing)
the test is whether the public benefit outweighs anti-competitive detriment associated with the
conduct. For all other forms of conduct (exclusionary provisions, third line forcing, resale
price maintenance and mergers), the test is whether the proposed conduct would result in such
a benefit to the public that it should be allowed to take place. The notification process is a
faster, cheaper and simpler way for obtaining immunity which is available for a limited range
of conduct. Until recently only exclusive dealing conduct could be notified. It is now also
possible for small businesses to notify collective bargaining conduct. Once notified, immunity
will occur immediately in the case of exclusive dealing (other than third line forcing) or after
14 calendar days for third line forcing and collective bargaining notifications, unless the
ACCC objects within that time. The Australian competition authority can only remove
immunity it if is satisfied that the public benefit will not outweigh the potential detriment
associated with the conduct.
There are a large number of exclusive dealing notifications involving supermarkets, primarily
relating to the offering of discounts conditional on purchases made elsewhere. For example,
the ACCC has, in the past, permitted major supermarkets to engage in exclusive dealing in the
form of offering petrol discounts contingent on purchasing a certain amount of groceries from
their supermarkets. These are generally referred to as ‘shopper docket’ schemes.
In a 2004 Report, the ACCC observed that it considered there were significant benefits to
consumers from shopper docket petrol discount schemes, in particular, lower petrol prices and
increased non-price competition. Subsequently, a 2007 Petrol Report also found the schemes
benefited consumers and promoted competition, observing that there had been over 600
notifications received by the ACCC since 2004 (until 30 September 2007), although not all of
these involve major supermarkets. The 2007 Report acknowledged, however, that ‘most
industry participants consider that the introduction of shopper docket arrangements has made
it harder for small independents with low volume sites to compete.’
Agricultural production in the United States remains strongly marked by cooperative
structures. Farming cooperatives have limited immunity from antitrust scrutiny by the
1922 Caper-Volstead Act.2 It is debatable today whether Capper-Volstead antitrust
immunity ultimately benefits most farmers or simply benefits the corporate heads of
large cooperatives.
 Several recent consolidated antitrust cases have challenged what
downstream purchasers believed were cooperatives restricting supply to maintain
higher prices for producers.
In France, according to Article L 420-4 of the Commercial Code, the prohibition of
anticompetitive practices does not apply to (i) those which result from the implementation of
a Legislation or Regulation adopted in application thereof; to (ii) those whose authors can
prove that they have the effect of ensuring economic progress, including by creating or
maintaining jobs, and that they reserve for users a fair share in the resulting profit, without
giving the undertakings involved the opportunity to eliminate competition for a substantial
part of the products in question. Similarly, agreements or concerted practices are not subject
to the provisions of Article L 420-2-1 of the Commercial Code when their authors can justify
8
that such agreements are based on objective reasons with respect to economic efficiency and
reserve for consumers a fair share of the resulting profit (Article L 420-4 of the Commercial
Code).
Aside from the individual exemptions previously mentioned, farmers’ groupings or
associations are also frequently exempted from competition law either because the de minimis
rules apply to them or because they benefit from a specific group exemption if they meet
certain criteria.
For example, in the Netherlands the de minimis rule applies also to hardcore violations of
competition law. Article 7 of the Dutch Competition Act exempts (i) all
agreements/decisions/concerted practices that involve no more than 8 undertakings, which
have a combined turnover that does not exceed EUR 5.5 million if they are involved in the
sales of goods or EUR 1.1 million in all other cases, and (ii) all
agreements/decisions/concerted between (potential) competitors provided that the combined
market share of the parties involved does not exceed 10% on any of the markets affected. This
second exemption was introduced in 2011. It aimed to strengthen the position of small and
medium sized undertakings inter alia against buyer power from large retailers.
In Hungary, the recently adopted amendment to the Act No. CXXVIII of 2012 regulating the
Conduct of Interbranch Organizations in the Agricultural Sector (“Interbranch Organizations
Act”) introduced new rules which include an exemption from the prohibition of
anticompetitive agreements and concerted practices in the field of agricultural products. Since
the scope of the Interbranch Organization also covers the processing stage of the product
chain, even wholesalers, multinational retail chains and food processors may benefit from the
exemption.
In Finland, the Finnish equivalent of Article 101 TFEU (i.e. prohibition on agreements
restrictive of competition) shall not be applied to arrangements by agricultural producers,
associations of agricultural producers, sector-specific associations, and any associations
formed by these sector-specific associations concerning the production or sales of agricultural
products or the use of common storage, processing or refining facilities if the arrangement
fulfills the substantive requirements established in accordance with Section 42 TFEU, under
which the rules on competition of Articles 101 and 102 of the said Treaty shall not apply. The
limitation in the scope of application regarding the agricultural activities only includes the
cooperation arrangements between the agricultural producers and the associations of
agricultural producers. Therefore, unlike the situation in Hungary, an agreement between, for
example, a producers' cooperative and a slaughter house does not fall under the scope of the
exemption. It must also be noted that the exemption does not cover the abuse of a dominant
position.
In Romania, Article 3 paragraph 3 of the competition law expressly provides that the
provisions the law are inapplicable to the sale of agricultural and food products by individual
agricultural producers when they sell their own production.
9
In Germany, a sector exemption for certain agreements between producers of agricultural
products is contained in Section 28 of the competition law. Also, the Market Structure Act
(MStG), the aim of which is to improve the market position of farms, enables producer
collectives to be set up and permits what is termed “dual membership”, i.e. membership of a
co-operative and of a producers’ union. Furthermore Section 3 of the competition law
contains a specific provision for small and medium-sized enterprises with requirements
which, if they are fulfilled, justify an exemption from the cartel prohibition.
In France, there is no formal exemption from competition law for the agricultural sector.
However the French Competition Authority considers that groupings of producers of
agricultural products can be exempted from competition rules because of their contribution to
economic progress for the commercialization of products, provided that their practices
remains proportionate to the objective. Furthermore Article L 632-2 II of the Rural Code
exempts from competition law agreements concluded within officially recognized inter-
professional organizations aimed at i) adapting supply to demand through a forecast of
demand and a coordination or planning of production, (ii) planning and restricting production
to improve the quality of products having, (iii) limiting production capacity, (iv) temporary
restriction of the entry of new firms based on objective criteria and implemented in a non-
discriminatory manner, or (v) at fixing sales price by producers or the price at which they will
buy back their production. No party to such an agreement should have a dominant position on
the relevant product market and those agreements have to be notified, after their conclusion
and before they are enforced, to the Minister of Agriculture, to the Minister in charge of the
Economy and to the FCA. In the dairy sector, Article L 632-14 of the Rural Code allows
inter-professional organizations to develop and issue information on products prices, without
these practices being subject to the prohibition of anticompetitive practices.
In Austria, certain agreements and practices concerning the production, supply, storage and
processing of agricultural products are excluded from the application of the Austrian Cartel
Act if they do not include price fixing and if competition can be upheld (cf., Sect 2 Austrian
Cartel Act).
Exemptions from competition law for groupings of small retailers
Just as farmers’ groupings are exempted from competition law to allow them to withstand the
pressure of large scale retailers, small retailers in voluntary chains or are also exempted from
competition law in some countries to allow them to better compete with large scale retailers.

For example, between 1993 and 2000, Sweden had a national block exemption for voluntary
chains of retailers (which applied to grocery retail chains), i.e. chain stores comprised of
independent retailers under common brand name, as opposed to corporate chains. This
national block exemption was targeted at smaller chains having up to 20 per cent market
share, whereby joint purchasing and marketing, co-operation on the determination of prices in
common marketing, common accounting and calculation standards, exclusivity on purchased
goods and co-operation regarding establishments, financial and administrative services for
10