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What's Wrong with Cartels?

Published online by Cambridge University Press:  01 January 2025

Jonathan Crowe
Affiliation:
Bond University
Barbora Jedličková
Affiliation:
Centre for Public, International and Comparative Law, T C Beirne School of Law, University of Queensland

Abstract

Cartels have a significantly negative impact on economic welfare. Anti-cartel competition law–such as the provisions of pt IV div 1 of the Competition and Consumer Act 2010 (Cth)–tries to tackle this negative impact through civil and criminal remedies. The prohibition of cartels is most commonly justified on economic grounds. However, reference is also often made to broader moral grounds for proscribing cartels–for example, it is commonly stated that cartels are deceptive, unfair or engaged in a form of cheating. This article advances a unified account of the moral status of cartels that integrates both economic and moral factors. It does so by emphasising the relationship of cartel behaviour to the moral duty to promote the common good. Cartels are wrong because they undermine the role of open and competitive markets as a salient response to an important social coordination problem in a way that leads to seriously harmful economic outcomes. This combination of factors supplies a robust justification for both civil and criminal sanctions in appropriate cases, thereby affording a principled foundation for the current framework of cartel regulation in Australia.

Type
Article
Copyright
Copyright © 2016 The Australian National University

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Footnotes

The authors would like to thank Angus MacCulloch for helpful comments, Angela Allen for research support and Xavier Goffinet for copyediting. An earlier version of this article was presented at the Law and Society Association of Australia and New Zealand Conference in Brisbane in December 2014. We are grateful to all who participated in the discussion.

References

1 Competition and Consumer Act 2010 (Cth) pt IV div 1 and s 45(2) (previously Trade Practices Act 1974 (Cth)). Provisions prohibiting cartels were also found in previous Commonwealth laws that encountered constitutional difficulties. The Australian Industries Preservation Act 1906 (Cth) was struck down in Huddart, Parker & Co Pty Ltd v Moorehead (1909) 8 CLR 330, while the Trade Practices Act 1965 (Cth) was read down in Strickland v Rocla Concrete Pipes Pty Ltd (1971) 124 CLR 468 and subsequently repealed.

2 Competition and Consumer Act 2010 (Cth) ss 44ZZRF–44ZZRG.

3 ACCC, Cartels <http://www.accc.gov.au/business/anti-competitive-behaviour/cartels>. For instance, the ACCC states that cartels decrease ‘infrastructure by rigging bids in public infrastructure projects which inflates costs and ultimately reduces the public sector capacity to invest in beneficial projects’.

4 European Commission, Cartels: Overview (16 August 2013) <http://ec.europa.eu/competition/cartels/overview/index_en.html>.

5 US DOJ, Mission (20 July 2015) <http://www.justice.gov/atr/about/mission.html>.

6 ACCC, above n 3.

7 405 US 233 (1972).

8 15 USC §§ 1–7 (1890).

9 15 USC §§ 41–58 (1914).

10 Ibid.

11 Federal Trade Commission v Sperry & Hutchinson Co 405 US 233, 241 (1972).

12 US DOJ, above n 5.

13 The Enterprise Act 2002 (UK) c 40, s 188(1) used to include the dishonesty requirement. This requirement was removed by the Enterprise and Regulatory Reform Act 2013 (UK) c 24, s 47, which entered into force in April 2014. See Whelan, Peter, ‘Section 47 of the Enterprise and Regulatory Reform Act 2013: A Flawed Reform of the UK Cartel Offence’ (2015) 78 Modern Law Review 493.CrossRefGoogle Scholar

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18 See, eg, Stucke, above n 15; Beaton-Wells, above n 15; Whelan, above n 16. Green's three-part framework considers culpability, social harmfulness and moral wrongfulness. It therefore provides scope to address both economic and moral dimensions of cartel behaviour, but it does not integrate economic harms with underlying explanations of moral wrongfulness in the same way as the theory advanced here. Green's framework also relies heavily on common sense understandings of moral norms, as opposed to underlying justifications.

19 See, eg, Bork, Robert H, The Antitrust Paradox (Free Press, 1978) 263–4Google Scholar; Hovenkamp, Herbert, Federal Antitrust Policy: The Law of Competition and its Practice (Thomson West, 4th ed, 2011) 146.Google Scholar

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21 We will not specifically analyse ancillary restrictions arising from other activities of the competitors, such as creating joint ventures or undertaking research to develop new technology. These restrictions, like cartels, can have anticompetitive implications; however, they are not introduced specifically to restrict competition and may offer a range of potential or actual social benefits. They are therefore classed as ancillary agreements and not naked collusion. Our analysis also excludes those rare cases of fair and efficient horizontal agreements that might, for example, fulfil the criteria in art 101(3) of the Consolidated version of the Treaty on the Functioning of the European Union [2012] OJ C 326/01.

22 Beaton-Wells, above n 15, 677.

23 CfAspromourgos, Tony, ‘On the Origins of the Term “Neoclassical”’ (1986) 10 Cambridge Journal of Economics 265CrossRefGoogle Scholar; Friedman, Milton, Essays in Positive Economics (University of Chicago Press, 1953) 343.Google Scholar

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26 Ibid 527.

27 MacCulloch, above n 16, 78.

28 OECD, above n 20, 5.

29 Werden and Simon, above n 16, 924.

30 Ibid.

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32 See, eg, Competition and Consumer Act 2010 (Cth) ss 44ZZRO–44ZZRP; Treaty on the Functioning of the European Union, above n 21, art 101(3); Commission Regulation (EU) 1217/2010 of 14 December 2010 on the Application of Article 101(3) of the Treaty on the Functioning of the European Union to Certain Categories of Research and Development Agreements [2010] OJ L 335/36; United States v Addyston Pipe & Steel Co, 85 F 271 (6th Cir, 1898), modified and affirmed in Addyston Pipe & Steel Co v United States 175 US 211 (1899).

33 See, eg, Competition and Consumer Act 2010 (Cth) ss 45, 47.

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36 Murphy, Mark C, Natural Law in Jurisprudence and Politics (Cambridge University Press, 2006) ch 3.CrossRefGoogle Scholar

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38 Ibid 86.

39 Ibid 88.

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44 Many Continental European competition law regimes differentiate between ‘unfair competition law’ and ‘competition law’, while common law systems tend to merge these two categories. For instance, as mentioned above, cartels are prohibited in the US under both s 1 of the Sherman Antitrust Act 15 USC §§ 1–7 (1890) and s 5 of the Federal Trade Commission Act 15 USC §§ 41–58 (1914), which prohibit ‘unfair methods of competition’.

45 See, eg, Hayek, above n 25.

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50 See, eg, Eucken, ‘What Kind of Economic and Social System?’, above n 46, 27–45; Gerber, above n 47, 41–3.

51 Eucken, ‘What Kind of Economic and Social System?’, above n 46.

52 Eucken, The Foundations of Economics, above n 46, 208–13, 242–73; Eucken, ‘What Kind of Economic and Social System?’, above n 46, 27–45; Gerber, above n 47, 44–54.

53 Gerber, above n 47, 44–5; Tumlir, Jan, ‘Franz Böhm and Economic-Constitutional Analysis’ in Peacock, Alan and Willgerodt, Hans (eds), German Neo-Liberals and the Social Market Economy (Macmillan, 1989) 135–6.Google Scholar

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55 Böhm, Franz, ‘Rule of Law in a Market Economy’ in Peacock, Alan and Willgerodt, Hans (eds), German Neo-Liberals and the Social Market Economy (Macmillan, 1989) 4852Google Scholar; Gerber, above n 47, 34–5, 45–8. The ordoliberals therefore rejected legal positivism, arguing that a concept of law focusing on formal sources ignores the critical role of underlying social norms in the legal order. See Böhm, Eucken and Grossmann-Doerth, above n 46, 17–18.

56 Cf Hayek, above n 34, ch 10.

57 Eucken, The Foundations of Economics, above n 46, 269–70; Gerber, above n 47, 43. The ordoliberal doctrine recognises that not every market can reach an equally competitive level. Factors such as barriers to entry and levels of demand determine the maximum potential for competitiveness. Some markets (such as the bread market) can be highly competitive, while others (such as the jet plane production market) can reach only a low level of competition.

58 Gerber, above n 47, 49–50.

59 Ibid 50–2.

60 For further discussion, see Jedličková, Barbora, ‘One Among Many or One Above All? The Role of Consumers and Their Welfare in Competition Law and Policy’ (2012) 33 European Competition Law Review 568, 573–5.Google Scholar

61 See Hicks, J R, ‘The Foundations of Welfare Economics’ (1939) 49 Economic Journal 696CrossRefGoogle Scholar; Kaldor, Nicolas, ‘Welfare Propositions of Economics and Interpersonal Comparisons of Utility’ (1939) 49 Economic Journal 549.CrossRefGoogle Scholar

62 Willgerodt and Peacock, above n 48, 7.

63 Gerber, above n 47, 52.

64 Ibid 37–8.

65 Ibid 38; Willgerodt and Peacock, above n 48, 8–10.

66 See, eg, Furse, Mark, The Criminal Law of Competition in the UK and in the US: Failure and Success (Edward Elgar, 2012) 2849CrossRefGoogle Scholar; Riley, Alan, ‘Modernising Cartel Sanctions: Effective Sanctions for Price-Fixing in the European Union’ (2011) 32 European Competition Law Review 551Google Scholar; Connor, John M, ‘Effectiveness of Antitrust Sanctions on Modern International Cartels’ (2006) 6 Journal of Industrial Competition and Trade 195.CrossRefGoogle Scholar

67 Furse, above n 66, 29.

68 CfMarshall, Brenda, ‘Criminalisation of Cartel Conduct: Compelling Compliance with Anti-Collusion Laws’ (2010) 3 Journal of the Australasian Law Teachers Association 11, 13.Google Scholar

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70 This is only a presumption. We do not mean to deny that, in some circumstances, it may be appropriate to impose legal liability on a person, even though she is not morally responsible. However, this kind of strict liability should not be imposed lightly. The presumption seems even more robust in the case of criminal sanctions than for civil remedies.

71 Crowe, Jonathan, ‘Does Control Make a Difference? The Moral Foundations of Shareholder Liability for Corporate Wrongs’ (2012) 75 Modern Law Review 159, 162.CrossRefGoogle Scholar

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73 Crowe, above n 71, 171–9.

74 CfHart, Henry M Jr, ‘The Aims of the Criminal Law’ (1958) 23 Law and Contemporary Problems 401, 424CrossRefGoogle Scholar; Beaton-Wells, above n 15, 679.

75 Sections 44ZZRF–44ZZRG.

76 Memorandum of Understanding between the Commonwealth Director of Public Prosecutions and the Australian Competition and Consumer Commission regarding Serious Cartel Conduct (2009) [2.3], [4.4]. For discussion, see Marshall, above n 68, 16–17.

77 See generally Hart, H L A, Punishment and Responsibility (Oxford University Press, 1968)Google Scholar; Duff, R A, Intention, Agency and Criminal Liability (Blackwell, 1990).Google Scholar

78 Sections 44ZZRF–44ZZRG, 79(1). See also at s 6(2)(g).

79 Ibid ss 44ZZRF–44ZZRG, 79(1); Criminal Code Act 1995 (Cth) ch 2.