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Competition Highlights –
ASEAN & Beyond
Introduction
Dear All,
A Happy New Year to all as we share the latest news from the
region. The festive season
was fairly busy with 2013 ending with a number of interesting
cases. It appears that 2014
will be as busy on the competition front across ASEAN. For
background, Rajah & Tann’s
“Competition Highlights – ASEAN & Beyond” highlights as
quick notes only, a number
of important competition related legal and economic developments
in ASEAN as well as
key jurisdictions such as the European Union, Australia, India
and the PRC.
The updates remind all of the importance of complying with
competition laws across
different countries, even as India penalises Etihad for
implementing a transaction before
clearance was given, Singapore issues a proposed decision in its
first international cartel
case, and the seemingly heightened use of leniency across
multiple jurisdictions.
Case and regulatory developments aside, the Rajah & Tann’s
Competition Practice has
been boosted with the addition of Principal Economist, Tanya
Tang. Tanya has nearly a
decade of experience working with the Infocomm Development
Authority and the
Competition Commission in Singapore. Tanya’s addition to the
team, at a time when
competition regulators are increasingly active, is welcomed.
Tanya is a valuable resource
that will contribute across our ASEAN network of firms and the
team will most certainly
benefit from her unique perspectives. The Practice has also been
boosted, with bigger and
stronger teams in Vietnam and in Thailand. Indonesia remains a
very strong practice with
top notch lawyers plus five economists on the ground.
We trust that you will find this issue informative, and we look
forward to any comments
and suggestions. Feel free to contact the lawyers in your
jurisdiction as set out at the last
page for your information.
Wishing you all a Happy and Prosperous Lunar New Year.
Kind regards,
Competition & Anti-trust Team
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Singapore
Board Changes At The Competition Commission Of Singapore
(“CCS”)
With effect from January 2014, Mr Aubeck Kam Tse Tseun joins the
CCS board. Mr Kam,
who currently serves as the Permanent Secretary of the Ministry
of Communications and
Information of Singapore, has replaced Mrs Tan Ching Yee who
stepped down on 31st
December 2013 when her term ended. There are no other board
changes and Chairman
Mr Lam Chuan Leong and the other board members remain in
office.
CCS Issues Proposed Infringement Decision Against Ball And
Roller Bearings
Manufacturers
On 16 December 2013, the CCS issued a Proposed Infringement
Decision (“PID”) against
four Japanese bearings manufacturers and their Singapore
subsidiaries (“Parties”). CCS
began its inquiry into the cartel after one of the companies
applied for immunity under
the CCS’ leniency program. In this preliminary decision, which
is CCS’ first infringement
case in an international cartel, the CCS held that by engaging
in “anti-competitive
agreements and unlawful exchange of information in relation to
the prices of ball and
roller bearings”, the Parties had infringed section 34 of the
Competition Act. The CCS, in
another first, has held both parents and subsidiaries would be
jointly and severally liable
for the infringement.
CCS Publishes Occasional Paper On Whether Buyer Power Can Be
Used As A Defence
On 8 January 2014, the CCS published an Occasional Paper
discussing whether Buyer
Power can be used as a Defence. “Buyer power” is defined as the
circumstance where “a
firm or a group of firms are able to obtain from suppliers more
favourable terms than
those available to other buyers or would otherwise be expected
under normal competitive
conditions”.
Using past cases in Singapore as case studies, the paper
discusses the possibility of raising
such a defence in relation to cases of abuse of dominance,
mergers and anti-competitive
agreements where, prima facie, the act would result in an
adverse effect on competition in
the market. It concludes that such a defence may be used to
avoid liability for
infringements in the following ways:
Abuse of dominance: the presence of countervailing buyer power
may be used to
argue that the undertaking is not in a dominant position and,
therefore, no abuse can
be found.
Mergers: the existence of countervailing buyer power may
minimize the risks of
coordination between the remaining undertakings post-merger. It
may also offset
non-coordinated anti-competitive effects so that no Substantial
Lessening of
Competition (“SLC”) will be found to result from the merger.
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Anti-Competitive Agreements: except for cases involving black
listed activities, buyer
power may be used to argue that there is no appreciable adverse
effect on competition
in the market. The presence of buyer power can also be used to
strengthen the case for
net economic benefit.
Malaysia
Malaysian Competition Commission (“MyCC”) Grants Conditional
Block Exemption
For Liner Shipping Agreements
On 19 December 2013, following studies into the shipping
industry and consultations with
stakeholders and relevant government agencies, the MyCC has
issued a conditional Block
Exemption Order (“BEO”) for liner shipping arrangements. The
agreements subject to the
exemption are Vessel Sharing Agreements (“VSA”) and Voluntary
Discussion
Agreements (“VDA”) between liner operators made within Malaysia
or which have an
effect on the liner shipping services in Malaysia. There are
various conditions attached to
the exemption of VSAs and VDAs including, inter alia, that they
do not contain any
elements of price fixing and are for a reasonable period of time
only. In addition, the
agreements have to be filed with MyCC.
VSAs and VDAs typically involve coordination between shipping
operators in respect of
their capacity and schedules and could involve the exchange of
detailed market and
commercial data. Such activities, if not otherwise exempted,
fall foul of section 4 of the
Competition Act 2010, which prohibits such anti-competitive
agreements. The decision to
exempt these agreements was because they gave rise to
significant identifiable benefits,
which include the frequency and quality of shipping services.
However, VSAs will not
benefit from the BEO if they contain arrangements on rates of
tariffs charged.
Notably, the BEO only exempts transport services provided by
liner operators for ocean
transport, and excludes intra-modal transport services. Thus,
any inland carriage of
goods, including services provided by logistics providers,
forwarders, depot operators,
truckers, railroads, off-dock consolidation service providers,
and off-dock storage and
warehousing service providers are not exempt. Separately, the
BEO does not provide
immunity where parties abuse their dominant position.
The proposed BEO was issued further to an application filed by
various associations in
Malaysia in December 2011. The BEO is expected to be in force
for three years from the
date the order is published in the Gazette, and will be reviewed
two years from the date of
its commencement. As at the date of this Update, the BEO has not
been gazetted.
MyCC Issues Draft Guidelines On Leniency And Financial
Penalties
On 15 January 2014, MyCC issued two separate sets of Guidelines
for public consultation :
the Draft Guidelines on Leniency and the Draft Guidelines on
Financial Penalties. Whilst
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the draft Guidelines on Financial Penalties are very brief and
do not provide much detail
on the aggravating and mitigating factors used by MyCC when
calculating the amount of
the fines to be imposed, the draft Leniency Guidelines include
details on the procedure to
be followed, the conditions that can be imposed on the leniency
applicant, and the stage at
which unconditional leniency will be granted. However, it is not
clear from the draft
whether leniency will only be granted to the first leniency
applicant or otherwise, a point
that will hopefully be addressed further to the public
consultation.
MyCC Probes Alleged Cartel Behaviour In Ice And Stationery
Markets
The MyCC has launched preliminary investigations into the ice
manufacturing and
stationery industries for alleged price-fixing. On 24 December
2013, 26 ice manufacturers
had published an advertisement in a local newspaper
advertisement their decision to
increase the prices of edible tube ice by 50 sen per bag and
RM2.50 per block from January
2014. In a similar move, on 27 December 2013, the Federation of
Stationers and Booksellers
declared that the price of stationery will be increased come the
first quarter of 2014.
On 21 January 2014, MyCC issued interim measures to prohibit the
26 ice manufacturers
from implementing the agreed price increase. No similar action
has been taken, as yet,
against the Federation of Stationers and Booksellers.
Schedule 1 To The Competition Act Amended
With effect from 1 January 2014, Schedule 1 of the Competition
Act 2010 has been
amended to exclude commercial activities regulated under the
Petroleum Development
Act 1974 and the Petroleum Regulations 1974 from the application
of the Competition Act
insofar as such activities are “directly in connection with
upstream operations comprising
the activities of exploring, exploiting, winning and obtaining
petroleum whether onshore
or offshore Malaysia”.
Indonesia
Proposed Acquisition Of PT. Perusahaan Gas Negara (“PGN”) By PT.
Pertamina
(“Persero”)
Following the Indonesian government’s approval for Persero’s
proposed acquisition of
PGN, the KPPU is closely monitoring the implementation of the
deal. PGN is Indonesia’s
largest natural gas transportation and distribution company
while Persero is a state-
owned oil and gas company, with its subsidiary, PT. Pertamina
Gas (“Pertagas”), in
charge of gas supply in Indonesia. While the purported aim of
the merger is to ensure
“open access” between the gas pipes infrastructure owned by PGN
and Pertagas so as to
strengthen national energy security, the merger will likely also
reinforce PGN’s dominant
position in the market for gas pipes infrastructure.
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KPPU Commences Investigations into Potential Irregularities in
the PT. Dayamitra
Telekomunikasi (“Mitratel”) Sale
The KPPU has announced that it has commenced investigations into
certain practices of
PT Telekomunikasi Indonesia, Tbk (“Telkom”), Indonesia’s largest
telecommunications
company. Specifically, the KPPU is reviewing the tender process
of Telkom’s subsidiary in
the telecommunications tower sector, Mitratel.
According to the Commissioner, Syarkawi Rauf, the KPPU believes
that Mitratel had
amended its tender process, but such amendments were not made
known to the KPPU.
Hence, the KPPU is interested in whether or not the amended
process had an effect on the
relevant market. This is primarily also because there is an
obligation on Mitratel to comply
with the relevant rules and regulations, and notify the relevant
authorities of any material
changes to its business processes.
The investigation by the KPPU into the tender processes of
Mitratel is supported by
Commission VI of the House of Representatives (“DPR”). Separate
from the
investigations, DPR stated that it had made an official request
to the Ministry of State
Enterprises to rescind the proposed sale of Mitratel, as the
sale may potentially result in
huge financial losses for Telkom. According to the DPR, the
potential losses suffered by
Telkom would have a detrimental effect on the country. In
support of its request, the DPR
further stated that the sale of Mitratel fell within the ambit
of Law No 17 of 2003
Regarding State Monetary Affairs. Hence, any such sale must
obtain the prior approval of
DPR.
Vietnam
3G Fee Hike Does Not Violate Competition Law
On 30 December 2013, the Vietnam Competition Authority (“VCA”)
dismissed allegations
that a recent simultaneous price hike in 3G data packages by the
country’s three largest
mobile network operators, Viettel, MobiFone and Vinaphone was
anticompetitive.
Specifically, the VCA found no evidence of collusion between the
three operators, noting
that: (i) each operator’s proposals for price increases were
lodged with the Ministry of
Information and Communications at different times; (ii) each
operator had submitted
different scheduled start dates and price increases for packages
other than 3G data
packages; and (iii) the common start date of 16 October selected
by all three operators for
their price hike was not the result of collusion but actually an
adherence to the common
practice where 3G tariffs are payable either in the beginning or
middle of the month.
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China
Beijing Court Issues Judgment Against Seafood Cartel
On 21 November 2013, the Beijing Second Intermediate People’s
Court ruled that a
horizontal agreement between members of the Beijing Seafood
Wholesalers’ Association
(the “Association”) to maintain minimum retail prices of
scallops from Zhangzi Island
and to prevent the sale of these scallops to non-members was in
violation of the
Antimonopoly Law. The Association was ordered to cease all
infringing conduct
immediately. This is the first reported case where a Chinese
court found and ruled against
a restrictive horizontal covenant. The Association has filed an
appeal against the decision.
China’s Top Antitrust Regulator Poised For Major Expansion In
2014
On 11 December 2013, Xu Kunlin, Head of the Bureau of Price
Supervision and Anti-
Monopoly at the National Development and Reform Commission
(“NDRC”) announced
in an interview with China Daily, that the NDRC will hire at
least 170 more employees in
2014. About 20 of these new employees will be based in Beijing
while the rest will join
local units to investigate anti-competitive practices. Xu said
that with more staff, the
NDRC can increase oversight over business practices that may
lead to ”unreasonably high
prices for consumers” especially in industries that ”harm the
consumers the most” such as
the aerospace, daily chemicals, automobile, telecommunications,
pharmaceuticals and
home appliances industries.
Other Jurisdictions
Europe
European Commission (“EC”) Fines Banks €1.71 Billion For
Participating In Cartels In
Interest Rate Derivatives Industry
On 4 December 2013, the EC announced that it has fined eight
international financial
institutions a total of €1,712,468,000 for their participation
in illegal cartels in markets for
financial derivatives traded in the European Economic Area
(“EEA”). Six of these
institutions participated in one or more bilateral cartel
involving interest rates derivatives
denominated in Japanese yen (“YIRD”) while four of them
participated in a cartel
involving interest rates derivatives denominated in Euro
(“EIRD”). Both cases had
surfaced further to leniency applications by UBS and Barclays
respectively.
With regard to the EIRD, traders from the four financial
institutions discussed trading and
pricing strategies and colluded to fix the Euro Interbank
Offered Rate, a daily reference
rate based on the averaged interest rates at which Eurozone
banks offer to lend unsecured
funds to other banks in the euro wholesale money market. In
relation to the YIRD, the
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traders exchanged information on their Japanese Yen London
Interbank Offered Rate
submissions.
Under the EC’s cartel settlement procedure, the fines imposed
were reduced by 10%.
However, proceedings are continuing against three financial
institutions which had
decided not to settle the case.
EC Fines Johnson & Johnson And Novartis €16 Million For
Delaying Market Entry Of
Generic PainKiller Fentanyl
On 10 December 2013, the EC announced that it has imposed fines
of €10,798,000 on the
US pharmaceutical company Johnson & Johnson (“J&J”) and
€5,493,000 on Swiss
company Novartis AG for colluding and entering into an
anti-competitive agreement to
delay the market entry of a generic version of the painkiller
Fentanyl in Netherlands. In
July 2005, after J&J’s patent expired, its Dutch subsidiary,
Janssen-Cillag (“JC”), entered
into an agreement with Novartis’ Dutch subsidiary, Sandoz, for
Sandoz not to enter the
market in exchange for monthly payments. The agreement
eventually only ended in
December 2006 when a third party launched a generic version of
the Fentanyl patch.
EC Clears Acquisition Of Nokia’s Mobile Device Business By
Microsoft
On 4 December 2013, the EC cleared Microsoft Corporation’s
proposed acquisition of the
majority of Nokia Corporation’s device and service businesses
(“D&S business”) under
the EU Merger Regulation. The D&S business comprises the
production and sale of
smartphones and feature phones. The EC concluded that the
proposed acquisition would
not raise any competition concerns, noting that:
the merged entity will continue to face strong competition in
the market, including
from Samsung and Apple,
the overlap between the merger parties’ activities was minimal,
and
post merger, Microsoft is unlikely to stop or deny the supply of
its operating systems
and related software to third party smartphones producers. This
is because Microsoft
is not a big player in the mobile operating systems market and
would need to leverage
on third party device suppliers to compete with other stronger
competitors.
EC Opens In-Depth Investigation (Phase II) Into Telefonica
Deutschland’s Acquisition Of
E-Plus
In December 2013, the EC started an in-depth investigation
(Phase II) into the planned
acquisition of E-Plus Germany by Telefonica Deutschland
(“Telefonica”).
Telefonica and E-Plus are currently competitors in the mobile
telephony services market
and the acquisition will “combine two of the four mobile
networks in Germany and create
a player of similar size to the currently two largest operators,
Deutsche Telekom and
Vodafone”. The concern is this could result in the elimination
of an important competitive
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force and lead to a SLC in the market. Additionally,
post-merger, the remaining mobile
network operators could have greater incentive to collude or
engage in anti-competitive
behaviour. The acquisition could also lead to fewer options for
mobile virtual network
operators and service providers to choose from and results in a
poorer bargaining position
for wholesale access terms. A decision is expected to be issued
by May 2014.
Australia
The Australian Competition and Consumer Commission (“ACCC”)
Challenges Laundry
Industry Agreement On New Products
The ACCC has filed proceedings in the Federal Court of Australia
against an alleged
”laundry detergent cartel” involving Australia’s leading
suppliers of laundry products,
Colgate-Palmolive (“CP”), PZ Cussons Australia (“Cussons”) and
Unilever. The case
commenced following an immunity application by Unilever under
the ACCC’s Immunity
Policy for Cartel Conduct.
The ACCC has alleged that the parties have agreed to cease the
supply of standard
concentrate laundry detergents from early 2009 and supply only
ultra-concentrate
detergents thereafter. The three suppliers also standardised
their ultra-concentrate
products to meet certain specifications across the full range of
their laundry products. CP
and Unilever are also being accused of sharing market sensitive
information, including on
the planned dates of price increases. According to the ACCC,
Woolworths, one of the two
largest supermarket chains in Australia, knowingly participated
in the laundry detergent
cartel by playing a key role in its implementation.
The ACCC Takes Action Against NSK For Alleged Car Parts
Cartel
The ACCC has filed proceedings against NSK Australia Pty Ltd
(“NSK”) in the Federal
Court of Australia alleging that NSK and at least two of its
competitors participated in a
cartel for the supply of ball and roller bearings used in
vehicles and industrial machinery
in 2008 and 2009. The cartel involved the exchange of
information on the companies’
future pricing strategies, with the aim to maintain /control the
price of bearings sold to
aftermarket customers.
India
Competition Commission Of India (“CCI”) Slaps Record Fine On
State Coal Producer For
Abuse Of Dominance
On 9 December 2013, the CCI imposed a penalty of 17.7 billion
rupees on state owned coal
miner Coal India (“CIL”) for abusing its dominant position by
imposing unfair/
discriminatory conditions in its Fuel Supply Agreements (“FSAs”)
with power producers
for the supply of non-coking coal. CIL had been criticised by
power companies for
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supplying inferior coal at higher prices and having
non-transparent contract conditions,
including those relating to the quality of coal.
In addition to imposing a financial penalty, the CCI issued a
cease and desist order and
directed modifications to the FSAs. CIL has since filed an
appeal with the Competition
Appellate Tribunal, challenging the CCI’s order.
Indian Government Exempts Shipping Vessel Sharing Pacts From The
Prohibition Of
Anti-Competitive Agreements
On 11 December 2013, following consultations with CCI, the
Shipping Ministry as well as
public stakeholders, the Corporate Affairs Ministry, renewed for
another year, its
exemption of Vessel Sharing Agreements (“VSA”) from the
anti-competitive agreements
prohibition of the Competition Act. However, the exemption for
Discussion Agreements
(“VDA”) was not renewed. VSAs are agreement allowing carriers to
share space in each
other’s vessels and, therefore, optimize capacity while VDAs are
agreements that allow
the exchange of market information between shipping parties. The
exemption of VSAs
applies to all liner operators that operate ships from any
Indian port, regardless of
nationality. To be availed of the exemption, parties are
required to file their VSAs with the
Director General of Shipping.
Etihad Airways’ Purchase Of Jet Airways Fraught With
Turbulence
In October 2013, the Indian Government approved Etihad Airways’
(“Etihad”) purchase
of a 24% stake in Indian carrier Jet Airways (“Jet”) in a US$379
million deal (“Deal”). The
Deal was subsequently approved by the CCI on 12 November 2013.
An appeal against
this decision has been lodged by an interested party.
Separately, on 19 December 2013, the CCI, despite the clearance,
fined Etihad 10 million
rupees under Section 43 of the Competition Act. This was because
Etihad went ahead with
parts of the Deal before CCI had approved the transaction, i.e.
what is commonly known
as gun-jumping. The fine relates to Jet’s sale of landing and
take-off slots at London’s
Heathrow Airport to Etihad pursuant to pacts entered into
between the two carriers on 26
February 2013. The CCI has clarified that the implementation of
the deal before clearance
would not impact the previous approval given for the Deal.
Japan
JFTC Issues Cease And Desist Orders And Fines To Engineering
Companies For Bid
Rigging
On 20 December 2013, the JFTC announced its decision to impose a
cease and desist order
and surcharge payments totalling ¥746.62 million on more than 40
engineering companies
for their involvement in bid-rigging practices on tenders
relating to the provision of
overhead transmission facility works and underground
transmission line works by the
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Tokyo Electric Power Company (“TEPCO”). The decision stems from
a series of on-site
inspections conducted in November 2012. According to the JFTC,
the engineering
companies colluded with one another by pre-assigning amongst
them the successful
bidders for these tenders.
TEPCO employees responsible for procurement were also found by
JFTC to have
facilitated the bid-rigging practices by inviting only a
selected few companies to
participate in the tenders, and assisting the engineering
companies in concealing their
anti-competitive conduct. JFTC has since urged TEPCO to improve
its bidding system and
to take appropriate measures to ensure that such violations of
competition law are not
repeated.
South Korea
Three Retailers Fined For Unfair Business Activities
On 20 November 2013, South Korea’s Fair Trade Commission
(“KFTC”) imposed a total
fine of ₩6.21 billion on three major retailers for engaging in
unfair business activities
prohibited by the Monopoly Regulation and Fair Trade Act. The
three retailers are Lotte
Department Store, a major department store chain in South Korea,
Lotte Mart, a chain of
convenience stores, and Homeplus, the South Korean subsidiary of
British retail giant
Tesco PLC.Lotte Department Store received the largest fine of
₩4.57 billion using its
market power to force smaller vendors to disclose sales
information of their products in
competing department stores. Lotte Mart was fined ₩330 million
for reportedly forcing its
suppliers to sponsor a golf tournament. Meanwhile, Homeplus had
to pay ₩1.3 billion for
reportedly using its market power to force smaller suppliers to,
among other things,
absorb the cost of delivery to consumers of purchased
products.
Fair Trade Commission Fines Automotive Parts Makers For Prices
Fixing
On 23 December 2013, the KFTC announced that it has imposed a
total fine of ₩114.6
billion on the South Korean subsidiaries of Japan’s Denso Corp
and Germany’s
Continental AG and Bosch GmbH for fixing prices of automotive
parts sold to Hyundai
Motor Co, a major South Korean automobile maker.
Taiwan
Fair Trade Commission Censures Apple Over Resale Price
Maintenance Of iPhones
On 25 December 2013, Taiwan’s Fair Trade Commission (“TFCT”)
fined Apple Inc.’s
subsidiary, Apple Asia LLC (“Apple”), TWD20 million for
interfering with the retail price
of iPhone handsets sold by Taiwan’s three main mobile service
providers. Under
distribution contracts that the three mobile service providers
entered with Apple, each
mobile service provider was to provide to Apple details of the
bundled mobile plans and
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retail price of iPhones that they intended to set for Apple’s
approval prior to listing the
iPhones for sale.
The TFTC noted that Apple violated Article 18 of the Fair
Trading Act which prohibits
resale price maintenance since Apple’s agreements with the three
mobile service
providers effectively meant it determined the retail price of
the iPhones. The TFTC also
stated that after the mobile service providers paid for the
iPhones handsets, these
handsets belong to the mobile service providers and they should
be able to freely decide
on the retail prices of these handsets.
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THE RAJAH & TANN LLP REGIONAL COMPETITION TEAM – PRIMARY
CONTACTS
For more information on issues arising in specific countries
please contact the persons below. For issues
arising in a country not listed below, please feel free to
contact the Singapore team in the first instance.
General Contacts
Rajah & Tann LLP
9 Battery Road #25-01,
Straits Trading Building
Singapore 049910
t (65) 6535 3600
f (65) 6225 9630
www.rajahtann.com
Competition & Antitrust Practice
Contact:
[email protected]
[email protected]
t: (65) 6232 0111 / 6232 0104
SINGAPORE
Kala Anandarajah
Partner (Head, Competition & Antitrust)
D (65) 6232 0111 F (65) 6428 2192
[email protected]
Dominique Lombardi
Partner (Foreign Lawyer)
D (65) 6232 0104 F (65) 6428 2257
[email protected]
MALAYSIA (associate firm)
Kuok Yew Chen
Partner
D (603) 2273 1919 F (603) 2273 8310
[email protected]
Yon See Ting
Partner
D (603) 2273 1919 F (603) 2273 8310
[email protected]
INDONESIA (associate firm)
Yogi Sudrajat Marsono
Partner
D (62) 21 2555 7812 F (62) 21 2555 7899
[email protected]
Eri Hertiawan
Partner
D (62) 21 2555 7800 F (62) 21 2555 7899
[email protected]
Rikrik Rizkiyana
Partner
D (62) 21 2555 9937 F (62) 21 2555 7899
[email protected]
Vovo Iswanto
Partner
D (62) 21 2555 7800 F (62) 21 2555 7899
[email protected]
VIETNAM
Lim Wee Hann
Partner
D (65) 6232 0606 F (65) 6225 7725
[email protected]
Bui Khuong Diem Hoan
Senior Associate
D (84) 8382 12673 x 15 F (84) 8382 12685
[email protected]
THAILAND
Sui Lin Teoh
Director
D (66) 2656 1991 x 111 F (66) 2656 0833
[email protected]
Nattarat Boonyatap
Director
D (66) 2656 1991 x 108 F (66) 2656 0833
[email protected]
CAMBODIA (associate firm)
Heng Chhay
Managing Partner
D (855) 23 215 734 F (855) 23 726 417
[email protected]
LAO
Desmond Wee
Partner
D (65) 6232 0474 F (65) 6428 2198
[email protected]
MYANMAR
Chester Toh
Partner
D (65) 6232 0220 F (65) 6428 2208
[email protected]
Nyein Kyaw
Managing Partner
D (959) 7304 0763 F (951) 657902
[email protected]
CHINA
Benjamin Cheong
Partner
D (65) 6232 0738 F (65) 6428 2233
[email protected]
Linda Qiao Lina
Senior Associate
D (86) 21 6120 8818 F (86) 21 6120 8820
[email protected]
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