A Professional Assessment of Competition Law Compliance Programmes in Nigerian Conglomerates

The enactment of the Federal Competition and Consumer Protection Act 2018 has created new legal compliance obligations for large Nigerian conglomerates operating across multiple market sectors, including merger notification requirements, prohibition of anti-competitive agreements, and abuse of dominance provisions. This study provides a professional assessment of competition law compliance programme design and implementation in eight major Nigerian conglomerates across consumer goods, manufacturing, and professional services sectors. Data were gathered through structured interviews with group legal counsels and compliance directors, supplemented by review of available compliance programme documents and FCCPC interaction records. Results indicate that competition compliance programmes are nascent in most Nigerian conglomerates, with only two of eight surveyed groups having dedicated competition law compliance policies. Cartel risk training is absent despite documented price-coordination practices in several industries. Merger pre-notification analysis is frequently conducted reactively rather than prospectively integrated into group acquisition strategy processes. The study concludes that competition compliance infrastructure in Nigerian conglomerates is insufficient relative to the legal risk created by FCCPA enforcement. Recommendations include a model competition compliance programme template developed by the Nigerian Bar Association, mandatory compliance programme disclosure as part of FCCPC merger notification, and FCCPC publication of competition compliance guidance for specific high-risk sectors including cement, pharmaceuticals, and telecommunications.

Keywords: competition compliance, FCCPC, anti-competitive agreements, conglomerates, merger notification