WORLD TRADE
ORGANIZATIONWT/WGTCP/W/86
22 September 1998
(98-3632)
Working Group on the Interaction
between Trade and Competition PolicyOriginal:  Spanish
COMMUNICATION FROM VENEZUELA
The following communication, dated 23 July 1998, has been received from the Permanent
Delegation of  Venezuela with the request that it be circulated to Members.
_______________
Report on Competition Policy in Venezuela
I. GENERAL FRAMEWORK
1. Historical background
The Law Promoting and Protecting the Exercise of Free Competition (hereinafter the
“LPPLC”),  which was passed on 1 January 1992, governs all matters relating to competition in
Venezuela.
The LPPLC deals with the right to economic freedom (the traditional modern extension of
freedom of industry and trade) enshrined in the Venezuelan Constitution of 1961.  The relevant
constitutional provision grants all individuals the right to choose, participate in and devote themselvesto the economic activity of their preference.  Article 97 of the Constitution bans the establishment of
monopolies, with the exception of those which the State may decide to set up for reasons of public
interest.
Nevertheless, the guarantee of the right to economic freedom was suspended just one day
after the Constitution was promulgated, and so it remained until 1991, when Venezuela began to open
its economy.  Suspension of the guarantee was seen as a necessary measure to legitimate all the State
intervention that took place during the 1960s, 1970s, and 1980s.
When the guarantee of economic freedom was restored as of 1991, it became necessary to
develop a regulatory framework whereby agents could develop their business capabilities and skills in
a market economy and, to that end, become more familiar with their obligations under the rule of law.
The Venezuelan policy to promote free competition and economic efficiency pursuant the LPPLC was
conceived in this way.
2. The Superintendency as an administrative market-policing agency
Article 19 of the LPPLC, provides for the creat ion of an agency to enforce the law, namely
the Superintendency for the Promotion and Protection of Free Competition (hereinafter called
“PRO-COMPETENCIA”).WT/WGTCP/W/86
Page 2
PRO-COMPETENCIA is an agency headed by a Superintendent which is responsible for
enforcing the Law and imposing any applicable sanctions on agents committing infractions
(Article 21).  This agency has wide-ranging investigative and decision-making powers, and those
under its administration are obliged to meet the information requirements it sets (Article 31).
Although PRO-COMPETENCIA is, for budgetary a nd administrative purposes, part of the
Ministry of Industry and Trade, it is functionally independent and its decisions cannot be changed by
any administrative authority, but only by jurisdictional means (Article 19).
Consequently, the LPPLC confers essentially tw o types of market oversight powers on PRO-
COMPETENCIA:  promoting and protecting free co mpetition.  The aim pursued through enforcement
of the LPPLC’s provisions is to protect and promote free competition and efficiency for the benefit ofconsumers and producers (Article 1).
In connection with the first function - prot ecting competition - PRO-COMPETENCIA acts as
an administrative policing agency to ensure proper market functioning and to sanction practices that
distort trade.  This involves establishing the powers of anti-trust agencies, such as supervising marketcompetition, and control and prevention of practices that could jeopardize effective market
functioning (e.g. collusion or monopolization of markets).
This function is particularly important in the Venezuelan context given the influence of public
policies implemented in the past in respect of corporate practices, generally favouring restrictions oncompetition.  Such policies did in fact generate incentives for the cartelization of entire industrial
sectors to back the import substitution model, whose major instruments were to raise trade barriers
and set overvalued exchange rates.
According to this rationale, achieving a more open economy by lowering or eliminating
barriers to trade has not been enough in itself.  The continuation of State-stimulated practices has
entailed a constant risk that tariffs would be privatized, i.e. that private agents might counteract the
synergies derived from the opening.  This is particularly evident in the persistently high market
concentration and limited competitiveness still seen in certain sectors of industry and services.
The second function conferred upon PRO-COMPETENCIA by the LPPLC is promoting the
market system as a way of organizing economic activity in Venezuela.  In carrying out this secondfunction, the Superintendency is authorized to part icipate in the design of institutional frameworks
consistent with a free market system, by preparing reports or opinions to guide regulatory activities by
other public agencies that could affect market competition.  Both functions are examined in detail
below.
II. PROTECTING FREE COMPETITION:  PROHIBITED BEHAVIOURS, REGIME OF
EXCEPTIONS, AND PROCEDURAL CONSIDERATIONS
The LPPLC applies to any public or private individual or body corporate carrying out
economic activities within the territory of the Republic of Venezuela (Article 4).  It encompasses any
act that could have an anti-competitive effect on the Venezuelan market, even when it takes placeoutside Venezuela.  The Law could therefore potentially have an extraterritorial impact.
Similarly, competition regulations call for the application of the aforesaid principles to acts
that have an effect on more than one market in the context of the Andean Pact.  In such cases, the
provisions of the Cartagena Agreement will be applied - i.e. Decision 285 of the CartagenaAgreement Commission - as the competent supranational agency in such matters (Article 2).WT/WGTCP/W/86
Page 3
1. Prohibited behaviours
The LPPLC contains two kinds of prohibitions.  Fi rst of all, it spells out a general prohibition
characterizing behaviour by its effects;  and secondly, it presents a list of specific prohibitions which
describe certain forms of association between independent economic agents that could eliminate
business rivalry between them.
The general prohibition (Article 5) of the LPPLC covers any behaviour or contract that has
the effect of limiting free competition.  This is a residual provision, so that behaviours not typified in
the chapter on specific prohibitions which could give rise to restrictions on free competition should be
evaluated in the light of this provision.
The specific prohibitions (Articles 6 through 17) typify business practices very precisely.
These may be classified in four major categories, as collusive practices, exclusionary practices, abuse
of dominant position, and economic concentration.
(a) Collusive practices
The LPPLC bans various structures of association that restrict rivalry among competitors.
Such associations may take various forms.  Collu sion, for instance, may occur pursuant to agreements
concluded within a professional association or corporation (Article 9).  The rationale behind the ban
on such agreements is attributable to the fact that when they are binding, they affect all the members
of the association.  This means that they have an effect similar to that of legislation creating
monopolies in which certain individuals are prevented from exercising their economic rights andcertain other individuals are accorded privileges.
The regulations on competition prohibit agreements or concerted understandings that may be
expressed or concluded tacitly by two economic agents with a view to restricting competition between
them.  By extension, the ban applies to any form of association to restrict supply, allocate markets, orlimit production so as to raise prices above their competitive level (Article 10).
(b) Exclusionary practices
Exclusionary practices have the effect of preventing an economic agent from exercising the
right to participate in a market.  Pursuant to Venezuelan legislation, an enterprise need not hold a
dominant position to be sanctioned for carrying out an exclusionary practice.  Similarly, the LPPLC
lists a number of forms of exclusion which are suspected of concealing a monopolistic intent.  Forinstance, behaviours which stand in the way of or prevent the entry or permanence of enterprises in
markets are banned, except when they occur by virtue of a right protected by law.  This is true where
legal protection confers a lawful monopoly, as is the case of protection accorded to patents and other
intellectual property rights (Article 6).
The LPPLC also bans such restrictive exclusionary practices as boycott.  In this case, market
exclusion requires the participation of two agents;  one to actually carry out the practice, and the other
to incite the first to do so (Article 7).
The LPPLC further bans any manipulation of factors of production, distribution or
technological development that could generate constraints on free competition with a view to
preventing the entry or permanence of an economic agent in the market (Article 8).
Finally, the regulations on competition also condemn behaviours that eliminate competitors as
a result of an unfair practice.  It is important to note that this ban offers a descriptive list of practiceswhich are considered unfair under the LPPLC.  These practices relate to deceptive advertising,WT/WGTCP/W/86
Page 4
product simulation, breach of industrial secrets, and generally any behaviour or initiative that thwarts
the legitimate expectations of agents in the market (Article 17).
(c) Abuse of dominant position
The LPPLC does not prohibit monopolies or dominant market positions.  In its narrative
portion, however, the Law sanctions the abuse of such a market position.  This prohibition is similar
to the ban in Article 86 of the Treaty of Rome, which spells out practices constituting an abuse of
dominant market position.  According to these provisions, no enterprise in a dominant position may
abuse that position in the market by imposing abusive or discriminatory conditions or by refusing to
negotiate with any client without justification (Article 13).
In the interpretation of this provision given by PRO-COMPETENCIA, it is important to note
that holding a dominant market position is not in itself a transgression of competition regulations.  In
order for the dominant position to become a violation it must be tied to a specific abuse, i.e. a harmful
behaviour typified in the Law that would not have occurred had effective competition existed in the
market concerned.
(d) Control of economic concentration
Another kind of practice regulated by the LPPLC has to do with mergers and acquisitions of
enterprises that generate restrictive effects on competition or create a dominant position in the market
concerned, particularly when they take place within a single economic activity (Article 11).
Nevertheless,  it is interesting to note that the First Court of Administrative Procedure, which
reviews the rulings of PRO-COMPETENCIA, considered it necessary to regulate this provision.1
This led to the issuance by the Executive Branch of Regulation 2 on Evaluation of the Operation ofEconomic Concentration.
2  This Regulation sets forth the elements of evaluation and defines the
concepts of relevant market and effective competition, which are indispensable in determining themarket impact of mergers and acquisitions.
2. Regime of Exceptions
The LPPLC empowers the Executive Branch to set regulations whereby activities which are
in principle at variance with the provisions of the Law (Article 18) may be permitted.  This provision,
developed in Regulation 1 of the Law
3, establishes a regime of exceptions for certain practices which,
although they formally restrict competition, offer economic efficiencies and other advantages thatwarrant being preserved for society.
Not all practices are eligible for such authorization, however.  Article 8 of Regulation 1 sets
forth the following exhaustive list of practice s that may be authorized by PRO-COMPETENCIA:
1. Agreements, decisions, collective recommendations or concerted practices between
competitors as defined in Articles 9 and 10 of the Law;
2. agreements, decisions, collective recommendations or concerted practices between
non-competitors as defined in Articles 9 and 12 of the Law, which prevent effective
competition and have significant effects on the relevant market;  and
                                                     
1 Ruling of the First Court of Administrative Procedure dated 6 March 1997, in the matter of Consorcio
Inversionista Fabril CIF.
2 Decree 1.311 dated  2 May 1996, published in  Official Gazette No. 35.963 on 21 May 1996.
3 Decree 2.775 dated  21 January 1993, publishe d in Official Gazette No. 35.202 on 3 May 1993.WT/WGTCP/W/86
Page 5
3. unilateral practices or behaviours as defined in Articles 6, 7 and 8 of the Law.
In order for a practice to be eligible for authorization, it must meet the conditions set by
Article 18 of the LPPLC and Article 10 of Regulation 1, which are as follows:
1. The reason for authorizing such activities must be to contribute to improving the
production, marketing and distribution of goods and the rendering of services or to
promote technical or economic progress;
2. the activities authorized must involve advantages to consumers or users;
3. the activities, and control over their implementation, must first be authorized by the
Superintendency;
4. the authorization is to contain only what is indispensable to achieve the objective
pursued;
Regulation 1 sets forth a legal regime of general and specific authorizations for practices
running counter to the LPPLC on the terms outlined above.  Under this regime, a behaviour that in
principle runs counter to competition regulations may not be subject to sanction.  The difference
between the general and specific authorizations is that the first exempt whole categories of restrictive
practices from the legal prohibition, while the second are individual and place the burden of proof on
the administered party, so that the latter is required  to show that the practice is eligible for the benefits
of the exception.
In connection with general authorizations, an exception of this type now exists for exclusive
distribution contracts4, defined as contracts concluded between a supplier and a distributor whereby
the supplier undertakes to supply or sell certain products exclusively to the distributor for resalewithin a given territory.  This exception exempts exclusive distribution contracts from the prohibition
stipulated in Article 10, point 3, of the LPPLC.  However, there are certain contracts to which the
general exception does not apply, inter alia :
(a) Exclusive distribution contracts in which the distributor is in turn a competitor of the
supplier in producing the products identified.
(b) Contracts for products that can only be obtained by clients through the distributor and
cannot be supplied with competing products within or outside the territory assigned.
(c) When the products identified in the contract are not subject, within the territory
assigned, to effective competition from competing products, i.e. are identical or
similar products by reason of their properties, uses and prices.
(d) Exclusive distributions whereby access to the relevant market by other suppliers of
competing products is restricted.
(e) Contracts whereby the supplier determines directly or indirectly prices or contract
conditions for resale to third parties of the products identified in the contract.
(f) Contracts concluded for an indefinite duration or for greater than five years.
                                                     
4 Resolution SPPLC/036-95 dated 28 August 1995, pu blished in Official Gazette No. 35.081 on
21 September 1995.WT/WGTCP/W/86
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3. Procedural considerations
The LPPLC establishes a different treatment for various acts by PRO-COMPETENCIA vis-à-
vis administered parties.  Various procedures are stipulated, according to whether one of the practices
specified in the competition regulations as competition-restrictive is involved, or a concentration
operation, or a behaviour that can be dealt with under the Regime of Exceptions.
With respect to the first, PRO-COMPETENCIA – either ex officio or at the request of one of
the parties – may initiate an administrative procedure.  In effect, the Superintendency may act on its
own initiative as a government attorney and at the same time as a kind of administrative court judge,
issuing rulings of a quasi-jurisdictional nature.  The procedure may also be initiated by a complaint.
In such cases PRO-COMPETENCIA acts in the same way as would a judge, from a position of
impartiality with respect to the interests of complainant and defendant.
The Superintendency is also authorized to impose sanctions on or order the behaviours of
economic agents that restrict the workings of the market.  The aim pursued in this procedure is to
determine the existence of competition-restrictive practices and, where applicable, sanction them and
order that they cease.  Two internal bodies take part in the administrative procedure:  the Office of theSuperintendent and the Competition Court.  The fi rst is empowered to rule on the facts proven by
means of the evidence produced by the parties or obtained at the request of  the presiding judge.
The administrative procedure provided for in the LPPLC consists of three stages.  First of all,
the procedure is initiated by an order issued by the Superintendent to the Competition Court.  Then,once the parties have been notified, the trial period, or period for furnishing proof, begins to run.  The
duration of this period is 15 business days, and may be extended for an equal period (Article 36).
Once this time has elapsed, the Superintendent has 30 business days to reach a decision (Article 37).
During the trial stage, PRO-COMPETENCIA may apply preventive measures by issuing
provisional orders to protect the market until such time as a final decision is reached.  As a general
principle, the following extremes must be demonstrated:  firstly, a presumption of  “sound law” and
secondly, the presumption that the decision is not likely to be executed if the measure is not applied.
The LPPLC contains no provisions governing evidence.  However, according to the
provisions on evidence set forth in the Law of Administrative Procedure, PRO-COMPETENCIA may
use any means of proof provided for in Venezuelan legislation to reach an administrative decision(Article 58 of the Law of Administrative Procedure).
The authorizations system provided for in the Regime of Exceptions calls for a different
procedure than the above.  To determine the ex istence of a restrictive practice under the LPPLC,
behaviours that may be eligible for a general exception must be distinguished from those subject toindividual authorizations, which require an individual analysis in order to be authorized by the
Superintendency.
The LPPLC stipulates that the procedure for authorization and other matters not expressly
provided for in the Law are to be governed by the applicable provisions of the Law of Administrative
Procedure (Article 42).  The Law allows a period of four (4) months, renewable, for processing of any
application through the administration (Article 60).  This period applies to the regime governing
control of economic concentration operations.WT/WGTCP/W/86
Page 7
Also in these operations, there is a “minimum rule” whereby an exemption from the
prevailing regime is allowed for certain operations in amounts less than those announced each year by
the Superintendency, so that only mergers in excess of the specified threshold are evaluated.5
In the case of concentration operations, administered parties are not required to notify that the
operation has taken place.  However, the Regime for Evaluation of Economic Concentration
Operations provided for in Regulation 2 allows agents to request ex ante  evaluations before carrying
out the operation.  Although the Regulation contains no express obligation, it does place a burden on
administered parties in the sense that if the concentration generates competition-restrictive effects,
PRO-COMPETENCIA may initiate a procedure after the operation takes place and apply sanctions.
III. VENEZUELA’S EXPERIENCE IN PROMOTING AND ADVOCATING
COMPETITION
Promoting competition by reformulating instituti onal rules plays a vital role in the policy of
PRO-COMPETENCIA, given the conviction that restri ctions on competition in Venezuela, as in other
developing countries, is fundamentally the result of government intervention rather than the dynamics
of the market itself.  Accordingly, lifting institu tional barriers to competition is a task essential to
PRO-COMPETENCIA’s activities.  These barriers not only result from excessive regulatory activity
by the State but may also be caused by the tendency of economic agents to follow the same traditions
that inhibit the creation and development of new market opportunities.
Imposing sanctions to protect competition would be futile or fall short of the mark were it not
for the existence of inductive mechanisms that can influence the institutional configuration – this is
what in the last analysis determines the desire of economic agents to compete or undertake alliances
to restrict competition.  Clear evidence of this are the continued forms of interaction among
enterprises in the context of professional associations or corporations.  These forms of negotiation,
once favoured and promoted by the State, have continued into the present even though the State hasceased to intervene proactively in them.  Hence the importance of a policy aimed at influencing, from
the same institutional sources, the behaviour of economic agents.
What is needed is active participation by th e Superintendency in the institutional framework
of economic activity, since a system to protect competition makes sense only within an institutional
framework that encourages entrepreneurial activity.
The conventional interpretation of anti-trust analysis is that the intensity of competition in a
market is related to its degree of concentration.  Such a view could introduce a dangerous bias in
assessing the advisability of sanctioning business practices in developing countries which, like
Venezuela, have undertaken to open their economies.  The obviously high degree of market
concentration in the developing countries inevitably leads to the impression that anti-trust policiesshould be particularly strict in such countries.  However, this is a slanted view of the problem, since
the institutional framework – which is ignored in such a conventional analysis – has a decisive
influence on whether the configuration of market structures is concentrated or deconcentrated.  An
analysis of institutions should therefore precede an analysis of market concentration.  Actions within
the institutional framework assume changes in the de gree of market competitiveness, since they affect
the structure of incentives faced by agents and the level of information that can be generated within
                                                     
5 Resolution SPPLC/14-96 dated 24 May 1996, published in Official Gazette No. 295287 on
15 July 1996;  Sole Article:  “Regulation 2 of the Law Promoting and Protecting the Exercise of FreeCompetition shall apply to all economic concentration operations where the total business volume of the
enterprises participating in the opera tion exceeds the equivalent of one hundred twenty thousand (120,000) tax
units…”.WT/WGTCP/W/86
Page 8
the system, which enables established markets to be “deconcentrated” through the development of
new markets.
This is the reason why PRO-COMPETENCIA ha s placed special emphasis on activities to
promote competition.  A policy to protect competition in countries characterized by concentratedmarkets, based on a traditional approach that does not consider the institutional context in which
enterprises interact, focusing on market features instead, would run the risk of providing an ongoing
alibi for State intervention:  precisely the opposite effect than is pursued by policies of economic
liberalization.
PRO-COMPETENCIA’s power to act as an advocate of competition proceeds from various
sources.  Firstly, the Law’s object assigns clear institutional responsibility for carrying out thisfunction.  Secondly, PRO-COMPETENCIA has receiv ed express authorization to issue opinions to
other agencies within the public administration and the judiciary (Article 29, point 1).
By virtue of that authority, competition advocacy has been manifested in several different
ways in Venezuela:  in privatization processes, in the analysis of sectoral legislation that could restrictcompetition, in the formulation of public policy pr oposals to promote competition in specific sectors,
in disseminating experience through the creation of university programmes, and through exchanges on
regulation experience with other competition promotion agencies.
1. Promoting competition in privatization processes
The Superintendency’s traditional activity to promote competition in privatization processes
consisted of applying an economic concentration analysis to the sale of public enterprises, as this
activity took place in other jurisdictions.
In this sense, the legislation governing privatization matters requires the Executive Branch to
prevent the establishment of monopolies in markets affected by the sale of enterprises.  When an
enterprise is privatized, i.e. when the ownership of assets is transferred from the public to the private
sector, changes in market structures are often introduced.  It is reasonable for the major stakeholders
in an enterprise slated for privatization to be enterprises that already participate in the market.
Although objectives of various kinds exist in privatization policy, assurances are needed that the
market situation to be generated as a consequence will be sustainable.
The Superintendency’s task in privatization processes is not confined to the auction of
enterprises.  In fact, since the auction process is a market in itself, the Superintendency ensures proper
implementation of the privatization process, understood as competition between enterprises to win the
auction.
Another area of action in privatization is the analysis of vertical integration models
characterizing a given enterprise.  An example is the auction of State enterprises in the aluminum and
steel industry, where prior studies were required to establish whether existing integration relations
might give rise to anti-competitive market structures following privatization.WT/WGTCP/W/86
Page 9
The table below shows the privatization operations analysed to date by the Superintendency:
Date Case evaluated Agency responsible Type of evaluation
22/10/93 Aeropostal Fondo de Inversiones de
Venezuela [Venezuelan
Investment Fund]Auction of enterprises
26/05/95 Indulac Venezuelan Investment Fund Bidding
21/02/96 Corporación Venezolana
de Guayana (aluminum)Venezuelan Investment Fund Evaluation of integration
models
Evaluation of contracts of
sale
12/04/96 Telecomunicaciones
Bantel, C.A.Deposit Guarantee Fund Auction of enterprises
23/04/96 Aeropostal Tenth Court of First Instance
in Civil, Commercial, and
Transportation Matters,
Metropolitan Caracas
jurisdiction6Auction of assets
11/06/96 Branches of Banco Latino Deposit Guarantee Fund Auction of assets
06/08/96 Seguros Nuevo Mundo Deposit Guarantee Fund Auction of enterprises
07/11/96 Banvalor Deposit Guarantee Fund Auction of enterprises
13/11/96 Seguros Profesional Deposit Guarantee Fund Auction of enterprises
29/11/96 S.A., Alucasa Deposit Guarantee Fund Auction of enterprises
16/12/96 Custodia y Traslado de
Valores [Securities
Safekeeping and Transfer]Deposit Guarantee Fund Auction of enterprises
26/05/97 Branches of Banco Latino Deposit Guarantee Fund Auction of assets
05/97 Corporación Venezolana
de Guayana (iron and
steel)Venezuelan Investment Fund Evaluation of integration
models
Evaluation of contracts of
sale
10/97 Radio broadcasters Deposit Guarantee Fund Auction of enterprises
11/97 Siderpro Deposit Guarantee Fund Auction of enterprises
2. Promoting competition in the analysis of draft sector legislation
Another key area of activity by the Superintendency in promoting competition has been the
analysis of draft legislation to regulate specific sectors.  In such cases, the Superintendency must
examine whether the provisions of the draft legislation under discussion contravene prevailing
standards of free competition.  PRO-COMPETENCIA has generally taken a preventive approach to
these cases, endeavouring to anticipate restrictions on the workings of markets that could beintroduced by legislative processes.
                                                     
6 In this case, the Superintendency was asked to join the Commission in prequalifying interested parties
to acquire the assets of Línea Aeropostal Venezolana, C.A.  The trustees in the bankruptcy of the commercial
company Línea Aeropostal Venezolana, C.A. requested legal authorization from the court hearing the
bankruptcy, pursuant to Article 975 of the Commercial Code, to sell the operating assets of the bankrupt airline.WT/WGTCP/W/86
Page 10
3. Promoting competition in designing institutional policies to promote competition in
various sectors
Finally, the Superintendency has more recently begun to draw up public policy reports
designed to promote competition in specific sectors.  These reports contain an analysis of the situation
in particular markets or industries and propose policy options consistent with market mechanisms.
They emphasize the institutional framework prevailing in such sectors, presenting them to public
opinion in an effort to give a conceptual dimension to public policy discussion.  This has proven to be
crucial in the discussion of legislation and regulations in the Congress and other bodies of the
Executive Branch.
4. Centre promoting business competition
One emerging initiative in promoting competition which complements previous initiatives is
the creation of a body entrusted with promoting business activity.  Consideration is being given to the
possibility of setting up a network of organizations, particularly those devoted to the development of
small- and medium-sized industry, where the Superintendency would prepare technical reports and
suggestions for promoting competition in specific sect ors.  This project is also backed by agreements
concluded with academic establishments offering graduate studies in administrative areas.  Thisinitiative is being designed to meet several objectives simultaneously.  On one hand it seeks to
complement, in practical terms, the work being done in drafting public policy reports in specific
sectors;  on the other, it is to be used as a tool to advertise and promote the importance of the free
market as a system organizing economic activity.
5. Dissemination activities
Lastly, two activities that warrant special consid eration in terms of disseminating information
on activities and spreading the discipline of competition:  organizing programmes and seminars on
aspects of competition policy and regulatory economics at various universities;  and designing
training programmes for officials from other competition promotion agencies either in existence orbeing created elsewhere in Latin America.
PRO-COMPETENCIA has encouraged the creati on of programmes with direct and indirect
links to studies of business competition in the Faculty of Law and the School of Economics,
respectively, of Andrés Bello Catholic University;  as well as in the School of Economics and the
Master’s Programme in Economic Theory and Policy at Venezuela’s Central University;  and in the
Public Policy and Business Administration progra mmes at the Institute of Higher Studies in
Administration.  All courses are given by pr esent or former Superintendency officials.
A similar approach has been taken in developing relationships with competition agencies in
other countries.  Programmes set up for competition officials provide training for Superintendency
officials at other agencies and training at PR O-COMPETENCIA for officials of other competition
protection agencies in countries with as yet little experience.
The main purpose of training provided for Superintendency officials has been to enable them
to learn how other agencies operate in the area of competition policy in order to establish comparative
frameworks of analysis, based on reciprocal experience, which can be incorporated into the agency’sprogrammes.  Training is provided for Superintendency staff through visits to foreign agencies and
the hiring of experts to give courses in Ve nezuela.  PRO-COMPETENCIA has already conducted
such exchanges with Canada, the United States, Spain, and Germany.
More recently, the Superintendency has undertaken a programme to train officials from
several Central American countries.  Two fellowship programmes have been set up:  a multilateralWT/WGTCP/W/86
Page 11
programme for government officials from member countries of the Central American Integration
Secretariat, and a programme for Nicaraguan officials in connection with that country’s initiative to
establish competition promotion regulations.
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