Commission européenne, DG COMP MERGER REGISTRY, 1049 Bruxelles, BELGIQUE  
Europese Commissie, DG COMP MERGER REGISTRY, 1049 Brussel,   BELGIË  
 
Tel: +32 229- 91111. Fax: +32 229- 64301. E -mail: COMP -MERGER -REGISTRY@ec.europa.eu.   EUROPEAN COMMISSION  
Brussels, 13.07.2022  
C(2022) 5120 final  
PUBLIC VERSION 
 
Securitas AB  
Lindhagensgatan 70  102 28 Stockholm  
P.O. Box 12307  
Sweden  
Subject : Case M.10594 – SECURITAS / STANLEY SECURITY  
Commission decision pursuant to Article 6(1)(b) of Council Regulation 
No 139/20041 and Article 57 of the Agreement on the European Economic 
Area2 
Dear Sir or Madam,  
(1) On 10 June  2022, the Commission received notification of a proposed 
concentration pursuant to Article 4 of Council Regulation (EC) No 139/20043 by 
which Securitas AB (‘Securitas’ or the ‘Notifying Party’) acquires within the 
meaning of Article 3(1)(b) of the Merger Regulation sole control of the whole of 
Stanley Black & Decker, Inc.’s Electronic  Security Business (‘Stanley Security’ or 
the ‘Targ et’) (the  ‘Transaction’).4 Securitas and Stanley  Security together are 
designated hereinafter as the ‘ Parties ’. The same concentration was notified to the 
Commission on 18 March 2022 but was subsequently withdrawn on 11 April 2022.  
                                                 
1  OJ L 24, 29.1.2004, p. 1 (the ‘ Merger Regulation ’). With effect from 1 December 2009, the Treaty on 
the Functioning of the European Union ( ‘TFEU ’) has introduced certain changes, such as the 
replacement of  ‘Community ’ by ‘Union’  and ‘common market’  by ‘internal market ’. The 
terminology of the TFEU will be used throughout this decision. 
2  OJ L 1, 3.1.1994, p. 3 (the ‘EEA Agreement’). 
3  OJ L  24, 29.1.2004, p. 1 (the ‘Merger Regulation’).  
4  Publication in the Official Journal of the European Union No C  236, 20.6.2022, p. 110.  
In the published version of this decision, 
some information has been omitted 
pursuant to Article 17(2) of Council 
Regulation (EC) No 139/2004 concerning 
non-disclosure of business secrets and other  
confidential information. The omissions are shown thus […]
. Where possible the 
information omitted has been replaced by ranges of figures or a general description.
 
2 1. THE PARTIES  
(2) Securitas  is a Swedish -based  security service provider offering services in over 
40 countries. It is active in the provision of a wide range of services, including 
manned guarding, aviation sec urity, electronic guarding, alarm monitoring and 
response, corporate risk management, fire services and other services such as 
parking and health and safety training.  
(3) Stanley Security, formerly operating under the brand name ‘Niscayah ’,5 is the 
electronic  security business of Stanley Black & Decker, Inc. and is  primarily active 
in the U.S. and the EEA, offering security systems for electronic guarding and 
related electronic security services of alarm monitoring and response worldwide , as 
well as packages a nd technology tailored to the healthcare sector in North America. 
2. THE CONCENTRATION  
(4) Based on an acquisition agreement entered into by the Parties on 8 December 2021, 
Securitas will acquire sole control over Stanley Security. The Transaction 
constitutes a c oncentration within the meaning of Article 3(1)(b) of the Merger 
Regulation.  
3. UNION DIMENSION  
(5) The undertakings concerned have a combined aggregate worldwide turnover of 
more than EUR 5 000 million ( Securitas : EUR […], Stanley  Security: EUR […]) 
and the aggregate Community-wide turnover of each of the two undertakings 
concerned is more than EUR 250 million (Securitas : EUR  […], Stanley  Security: 
EUR […]). Neither of the undertakings concerned achieves more than two-thirds of 
its aggregate Union-wide turnover within one Member State. The Transaction thus 
has a Union dimension within the meaning of Article 1(2) of the EU Merger 
Regulation.  
4. RELEVANT MARKETS  
4.1. Introduction  
(6) The Transaction concerns the security services sector. In the EEA, Securitas 
provides primarily manned guarding , as well as alarm monitoring and response  
services , installation and maintenance of electronic guarding equipment and 
aviation security. Stanley Security, for its part, focuses mostly on electronic 
security. In the EEA, it offers  primarily alarm monitoring and response services 
and the installation and maintenance of electronic guarding equipment .  
                                                 
5  The Commission issued a clearance decision dated 2 August 2011 in M.6292 – Securitas/Niscayah 
Group (‘Securitas/Niscayah ’). However, the concentration between Securitas and Niscayah Group 
was not consummated  because Stanley Black & Decker outbid Securitas and purchased Niscayah 
instead, The Commission cleared the acquisition of Niscayah by Stanley Black & Decker  through a  
simplified decision dated 23 August 2011 in M.6326 – Stanley Black & Decker/Niscayah Group . As 
such, the Transaction constitutes the second attempt of Securitas seeking to acquire the electronic 
security business that it divested in 2006.  
3 4.2. Product Market Definition  
4.2.1. The Commission’s  past  decisional practice  
(7) In previous decisions,6 the Commission took the view that  within th e market for the 
provision of security services, (a ) manned guarding, (b) alarm monitoring and 
response, (c ) installation and maintenance of electronic guarding equipment (or 
‘electronic guarding ’) and (d) aviation security services provided to airports and 
airlines constitut e distinct product markets. 
(8) In particular, according to the Commission’s past decisional practice:  
(a) the provision of m anned guarding services covers services such as uniformed 
on-site guards and retail guards, key-holding services, contract project 
security, and events security and crowd management;7  
(b) alarm monitoring and response consists of receiving electronic data in an 
Alarm Receiving Center (‘ARC ’ or Security Operations Centre , ‘SOC’)  
connected to a site of a  customer, and reacting to any abnormal event 
detected by the alarm system of the site  (“alarm monitoring services”). The 
action to be taken by the provider of alarm monitoring services when an 
abnormal event is detected can either be a phone call to the c ustomer, to the 
police or to another security company or an "outside response", which involves sending staff on-site. Alarm response services consist in the 
provision of such “ outside response ” services ;
8  
(c) the installation and maintenance of electronic gua rding equipment comprises 
the installation and maintenance of alarm systems such as access control and fire alarm or video surveillance systems at a customer’s site(s);
9 and,  
(d) aviation security services to airports and airlines comprising elements of  
manned guarding and of electronic guarding security controls  specifically  for 
passengers.10  
(9) Moreover, the Commission considered whether to include  alarm response as part of 
manned guarding instead of alarm monitoring and response, leaving however, the 
exact market definition open in the absence of competition concerns.11 
(10) Finally, the Commission previously found that electronic guarding and alarm 
monitoring and response services could each be further divided into two sub-
market s depending on the type of cust omers, i.e., residential and non-residential, 
although it ultimately left the market definition open.12  
                                                 
6  M.6292 – Securitas/Niscayah Group,  decision of  2 August 2011, paragraph 8 ; M.9559 – 
Telefonica/Prosegur/Prosegur Alarmas Espana, decision of 19 February  2020, paragraph 14; M.3396 
– Group 4 Falck/Securicor, decision of 28 May 2004, paragraphs 29 and 31 ; and M.5993 –  
Securitas/Reliance Security Services, decision of 9 November 2010, paragraphs 12 -15. 
7  M.6292 – Securitas/Niscayah Group,  decision of 2 August 2011, footnote 5.  
8  M.6292 – Securitas/Niscayah Group,  decision of 2 August 2011, paragraph 9 and ff.  
9  M.6292 – Securitas/Niscayah Group,  decision of 2 August 2011, paragraph 13 and ff.  
10  M.3396 – Group 4 Falck/Securior, decision  of 28 May 2004, paragraph 30.  
11  M.5993 – Securitas/Reliance Security Services, decision of 9 November 2010, paragraphs 15 -17. 
12  M.6292 – Securitas/Niscayah Group,  decision of 2 August 2011, paragraph 15; M.4986 –  
EQT  V/Securitas Direct, decision of  31 January 2008, paragraphs 12- 14.; M.9559 –  
Telefonica/Prosegur/Prosegur Alarmas Espana, decision of 19 February 2020, paragraph 25.  
4 4.2.2. The Notifying Party’s view  
(11) The Notifying Party agrees  that the installation and maintenance of electronic 
guarding  equipment,13 as well as the provision of aviation security services (i.e. due 
to the special nature of the aviation industry and services, and the specific 
regulations that apply to this sector),14 constitute plausible relevant product 
market s. Moreover, the Notifying Party agrees  that manned guarding15 constitutes a 
separate relevant product market.16  
(12) However , although  the Notifying Party considers  alarm monitoring and response as 
a possible relevant product market , it considers  it would be more appropriate to 
treat alarm response as part of the manned guarding market .17 This is because, from 
a supply-side perspective, alarm response services and manned guarding services 
require the same resources, such as security personnel, vehi cles and a regional 
branch, whilst from a demand-side perspective, customers commonly purchase 
manned guarding and alarm response together in single packages.18 
(13) The Notifying Party further submits that the sub-segmentation of the installation 
and maintenanc e of electronic guarding equipment and alarm monitoring and 
response  markets by residential and non-residential customers would not be 
appropriate , because  from a supply- side perspective , the services provided and the 
technologies  and equipment involved are essentially the same for both types of 
customers.19 In addition, the Notifying Party claims that most market participants 
tend to target the entire market, rather than focusing on non-residential or residential customers only.
20  
(14) For the same reasons, the Notifying Party submits that  the installation and 
maintenance of  electronic guarding equipment and the alarm monitoring and 
response markets to non-residential customers should not be further sub-divided 
depending on the complexity of customers’ needs ,21 namely between non-
residential customers with standard and speciali sed security needs ,22 and depending 
on the geographic coverage of the services, namely between non-residential customers with national coverage  needs  and those with no such needs .
23  
4.2.3. The Commission’s assessment  
(15) Based on the results of its market investigation, t he Commission reaches the 
following conclusions .  
(16) First, in the present case, there is no reason for the Commission to depart from the 
previous segmentation of the market for t he provision of security services between: 
(i) manne d guarding ; (ii) alarm monitoring and response ; (iii) installation and 
maintenance of  electronic guarding  equipment ; and (iv) aviation security 
                                                 
13  Form CO, paragraph 138.  
14  Form CO, paragraph 256.  
15  Form CO, paragraph 246.  
16  Form CO, paragraph 247.  
17  Form CO, parag raph 182 and 196.  
18  Form CO, paragraph 267.  
19  Form CO, paragraph 216 and ff.  
20  Form CO, paragraph 211 and ff.  
21  Form CO, paragraph 218.  
22  Form CO, paragraph 231.  
23  Form CO, paragraph 241.  
5 services .24 This is because these services are complementary in nature ,25 and are 
not substitutable from a demand-side  perspective,26 whilst from  a supply- side 
perspective, although a number of security service providers offer a range of these 
services, each of them requires different skillsets and competences.27  
(17) This is reflected from the responses to the Commission’s market investigation. For 
instance, a  respondent explains that : “it is correct to subdivide the security market 
into manned guarding, alarm monitoring and electronic guarding. From the costumers’ perspec tive these are complementary services rather than substitutes.  
For example, the installation and maintenance of a thorough alarm, camera and 
access system cannot replace an alarm monitoring central, they are 
complementary. With respect to manned guarding i n relation to alarm monitoring, 
even if there might be a trend for guarding from a distance, through e.g. camera observations, this has yet not replaced the customers’ need for manned guarding, 
i.e., having physical guards present or nearby its buildings and sites.  The trend that 
manned guarding is being replaced by technical remote guarding is however 
ongoing, and an important rational behind the Transaction for Securitas. Also, 
from a supply side perspective these services require different types of skill  sets and 
competences for the supplier ”.
28 Furthermore, as regards security services to 
airlines and airports, another respondent  explains that: “Aviation security is a very 
specific type of security as it relates to terrorism and takes place in an open 
environment with public access, requiring large volumes of people and with highly 
demanding customers ”.29 
(18) Second, alarm response belong s to the alarm monitoring and response market, 
instead of being a segment of manned guarding. This is because, from a supply-side perspective, certain security service providers, including Securitas, offer alarm response services in-house, whilst others , including Stanley Security, often 
outsource alarm response instead of providing these services themselves, and then 
offer a contract for both services to the customer.
30 Consequently, t he lack of own 
personnel or a regional branch does not preclude security companies from offering 
response services together with monitoring services . In addition, this market 
dynamic also suggests that there is a vertical link  within the alarm monitoring and 
response market, namely between the provision of alarm response services 
purchased by  security service providers  (upstream) and the provision of alarm 
monitoring and response to end-customers  (downstream). Furthermore , from a 
                                                 
24  The Commission notes that a respondent to its market investigation suggests that alarm monitoring 
and response services together with the installation and maintenance of electronic guarding equipment should be considered as a single product market (Response to question 4.1 of questionnaire Q6 to competitors) . This is because, according to this respondent,  certain security 
service providers only offer these products tied (Response to question 4.1 of questionnaire Q6 to competitors). However, the Commission does not find this segmentation appropriate, because t he 
results of the market investigation suggest that customers purchase different security services in different ways, and potentially from different suppliers depending on their needs, and therefore, it is not the norm that alarm monitoring and the install ation and maintenance of electronic equipment are 
bought as a bundle. For example, a nother  respondent explains that : “[n]ot all clients need the whole 
package of services, so there will always be competition on the service layers. And as a customer you can decide to work with several suppliers if preferred.” (Response to question 19.1 of 
questionnaire  Q5 to customers in Belgium) . 
25  Responses to questions 4 and 4.1 of questionnaire Q6 to competitors . 
26  Responses to questions 4, 4.1, 8 and 8.1 of questionnaire Q6 to competitors.  
27  Responses to questions 4 and 4.1 of questionnaire Q6 to competitors.  
28  Response to question 4.1 of questionnaire Q6 to competitors.  
29  Response to question 8.1 to questionn aire Q6 to competitors.  
30  Form CO, paragraph 201.  
6 demand-side perspective, a larger number of customers buys alarm response 
together with alarm monitoring (on average [60-70]%, ranging from [20-30]% in 
the Netherlands to [90-100]% in Finland)31 compared to those who purchase it 
together with (on-site)  manned guarding (on average [10-20]%, ranging from 
[0-5]% in the Netherlands to [customers’ information] in Norway).32  
(19) Third , the markets for alarm monitoring and response  and the installation  and 
maintenance of electronic guarding  equipment  should be further segmented 
depending on the type of customer,33 i.e. between residential and non-residential  
customers .34 Although certain respondents explai n that “ distinguishing the market 
by reference to residential or business customers is not always appropriate ” 
because “ the services provided in this regard are essentially the same for both 
categories of customers ”,35 the vast majority of respondents, both customers and 
competitors, argue otherwise. For instance, a customer  explain s that: “[g]enerally 
speaking, where a company is working within the residential market then they will not have the capability or scale to support our specialised business functions. 
When procuring such services, [the customer] rel[ies]  heavily on corporate 
capabi lities, including; certain accreditation requirements for facilities, scalability 
where needed, extensive control room capabilities and monitoring requirements 
which are in no way comparable to a residential or domestic setting. It is difficult 
to envision a commercial customer relying on a residential provider. That said, 
there may be scope for a residential customer to rely on a commercial provider 
however this will be driven by various different factors (i.e. location, proximity to 
response and service)” .
36 The same view is supported by the vast majority of 
competitors who responded to the Commission’s market investigation, suggesting that there are differences between the products and services offered to residential and to non-residential customers, in te rms of pricing levels, IT infrastructure and 
variety of products and services offered, the levels of certification of the electronic 
guarding equipment, and the reaction time of the ARC among  other factors .
37 
(20) Additionally , the segmentation between residenti al and non-residential customers is 
also supported by internal documents of the  Parties , prepared in the ordinary course 
of business.38 These documents indicate that the complexity of the security service s 
                                                 
31  Form CO, paragraph 185 and Table 6.4; and responses to questions 6, 7.1 and 7.2 of questionnaires 
Q1-5 to customers.  
32  Form CO, paragraph 186 and Table 6.5. 
33  In line with the Commission’s past dec isional practice, this decision does not discuss the 
segmentation of the market for the provision of manned guarding services per type of customer (i.e. between residential and non -residential customers), as this service is almost exclusively 
purchased by non-residential customers. ( M.6292 – Securitas/Niscayah Group,  decision of 
2 August  2011, paragraphs 14- 15).  
34  Response to questions 5 and 5.1 of questionnaire Q6 to competitors.  
35  Response to question 5.1 of questionnaire Q6 to competitors.  
36  Respon se to question 4.5 of questionnaire Q1 to customers in Sweden.  
37  Response to question 5.1 of questionnaire Q6 to competitors.  
38  Response of the Notifying Party to Request for Information I -8, Annex Stanley 16.vi.51, Swinmar k  
Update  for Nordic  MT, dated June  2018, page 9; Response of the Notifying Party to Request for 
Information I-9, Annex 1, Market  matrix , dated August  2001, page 3; Response of the Notifying 
Party to Request for Information I -9, Annex 2, Market  matrix , dated March  2005, page 22; and, 
Response of the Notifying Party to Request for Information I -9, Annex 5, Market  matrix , dated 
February  2011.  
7 varies according to the type of customer and that s ome competitors focus on 
residential customers while others focus on non-residential customers .39  
(21) Four th, on the basis of the results of the market investigation, the Commission 
considers that  the market for the provision of alarm monitoring and response  to 
non-residential customers  and the market  for installation and maintenance of 
electronic guarding equipment for non-residential customers should not be further 
segmented  (i) based on the complexity and scope of customers’ needs  (between 
standard and specialised security needs ) or (ii) based on the geographic coverage of 
the services, in particular national coverage needs.  
(22) On the one hand, there are certain factors indicating that such differences in 
complexity of non-residential customers’ ne eds could lead to defining separate 
product markets.  
(23) In the  first place, the alarms systems installed and maintained by security service 
providers are classified based on their complexity, based on certain regulatory 
standards  (e.g. SSF 130 regulations  in Sweden, FG Skadeteknikk’s grades  in 
Norway), that govern their complexity, design and installation requirements.40 This 
suggests that, from a demand-side perspective, customers procure different alarm systems depending on their protection needs.
41 This is also supp orted by the 
responses to the Commission’s market investigation,42 where virtually all 
competitors and the vast majority of customers express a view that there are non-
residential customers in the alarm monitoring and response and installation and 
maintenan ce of electronic guarding equipment , with specialised security needs.43 
Moreover, the results of the market investigation suggest that, from a supply side  
perspective, not all security service providers have the ability and expertise to offer 
installation and maintenance of electronic guarding equipment for alarm systems of the highest classification levels ( e.g. Alarm Levels 3 -4 in Sweden and FG3 B2- 
FG3 B 3 in Norway).  
(24) In the  second place, there exist certain non-residential  customers that operate sites 
nation-wide, and require national coverage when procuring security services.
44 
Internal documents of Securitas prepared in the ordinary course of business s uggest 
                                                 
39  Response of the Notifying Party to Request for Information I -8, Annex Stanley 16.vi.49, M. Kushner 
visit Stockholm, dated S eptem ber 2019, page 8; Minutes of a conference call with a competitor, dated 
5 April 2022, paragraph 4; and Minutes of a conference call with a competitor, dated 6 April 2022, 
paragraphs 3 and ff.  
40  Response of the Notifying Party to Request for Information I -8, paragraph 25 and ff.  
41  The Notifying Party submits that an alarm system of the lowest classif ication level (e.g. Alarm 
Level  1 in Sweden, FG1 Grade in Norway) would be characterised by low complexity, and would be 
installed in the sites of SMEs with low protection value (i.e. needs similar to those of residential customers), whilst an alarm system of medium -to-high classification level (e.g. Alarm level 3 in 
Sweden, FG3 B2 Grade in Norway) would be more complex and installed in the sites of businesses with high value to protect . (Response of the Notifying Party to Request for Information I -8, 
Tables  5.1 and 5.2) . 
42  Responses to questions 5.2 -5.4 of questionnaires Q1- 5 to customers; Response to questions 6 -6.4 of 
questionnaire Q6 to competitors. 
43 A res pondent explains the factors that differentiate the needs of non -residential customers, indicating 
that “ [t]he requirements for the services vary depending on the business's protection value, what the 
company's disaster recovery plans look like and whether  the business has requirements for security of 
services or information from customers, authorities, legislators or insurance companies. Some activities also require the authorities to have guards with special powers and weapons ” (Response  to 
question 6.4 of questionnaire Q6 to competitors). 
44  Response to question 35.1 of questionnaire Q6 to competitors.  
8 that the company acknowledge s the existence of customers with “ national 
accounts ” and follows a specific  business strategy for those customers  
(e.g. assigning Key Account Managers for each client with national coverage 
needs).45 Moreover, the Commiss ion’s market investigation confirms that from a 
supply side perspective, the competitive landscape differs for those non-residential 
customers with national coverage needs, as not all security service providers are 
active nation -wide  and thus only “ few sup pliers can provide a national 
coverage ”.46 Finally, from a demand-side perspective, the vast majority of 
customers with national coverage needs procure these services via a singl e nation-
wide contract.47  
(25) On the other hand, the Commission notes that the re wo uld be considerable  
difficulty  in defining the exact  scope  of potential sub-markets according to the 
complexity and geographic scope of customer needs. Rather, there is a continuum 
of service needs, each customer may at the same time have simple and complex 
security needs and a multitude of factors influence each customer’s  needs , 
including the geographic location of their sites . 
(26) In the first place, it is not possible to identify clear dividing lines between 
customers with complex security needs and t hose without such complex security 
needs. For instance, different sites of the same customer’s business may have 
different needs  and/or business es that otherwise seem similar in their needs, for 
instance due to the number of sites or the type of business t hey pursue (e.g. retail) 
may have very divergent security needs depending on the value they need to protect. Furthermore, according to internal documents of the Parties prepared in the 
ordinary course of business, alarm monitoring and response  is a “ differ entiated ” 
market,
48 which  serves a variety of customers with different levels of security 
needs , rather than a market clearly divided into separate customer classes .49  
(27) In the second place, it is equally difficult to clearly distinguish and identify 
customers with national coverage needs. Each customer’s needs will depend on the 
location of its business sites. Those sites may have a clearly local coverage or 
clearly national coverage but there are also a large number of variations in between. That includes instances where the customers’ sites would be located in 
two or three different municipalities, but not in a large number of them. 
(28) In addition, the market investigation was not conclusive on whether customers with 
national coverage needs would consider contracting with numerous local suppliers 
as a substitute to contracting with a supplier with national coverage. For example, a customer explains from the one hand that, “scale is also an important factor for 
[the customer]  when cho[o]sing a security services p rovider. In particular, 
because of [the customer] ’s nationwide presence, the security services provider 
                                                 
45  Response of the Notifying Party to Request for Information I -8, Annex Securitas 16(vi)4, Securitas 
Norway Business Plan for 2021, dated September 2020, page 19.  
46  Response to question 52 of questionnaire Q6 to competitors.  
47  Responses to questions 9.1- 9.3 of questionnaires Q1- 5 to customers.  
48  Response of the Notifying Party to Request for Information I -8, Annex Stanley 16(vi)18, ‘Electronic 
Securi ty Strategic Plan’, 30 July 2019.  
49 Response of the Notifying Party to Request for Information I -9, Annex 1, Market Matrix, dated 
August 2001, slide 3; Response of the Notifying Party to Request for Information I -9, Annex 2, 
Market Matrix, dated March 2005, slide 22; Response of the Notifying Party to Request for 
Information I -9, Annex 5, Market Matrix, dated February 2011, slides 12 and 14.  
9 needs to have a national footprint as well (…).”.50 On the other hand, a competitor 
of the Parties explains that customers can “ switch suppliers and based on their 
procurement strategy either go with one or multiple suppliers ”51 in order to cover 
their needs.  
(29) Therefore, for the purposes of this decision, the complexity and geographic scope 
of the needs of non-residential customers will not be considered as bases for 
separate sub-markets , but as factors leading to differentiated service offerings in 
the market. These  plausible segments will be considered as differentiating factors 
in the a larm monitoring and response  market for non-residential customers  and the 
market for installation and in the maintenance of electronic guarding equipment for 
non-residential customers  in the competitive assessment below .  
(30) Fifth , in the market s for installation and maintenance of electronic guarding 
equipment  for residential a nd non-residential customers , some security service 
providers  outsource these services to third party providers  (e.g. in order to 
complete their product portfolio or increase the geographic scope of the services they provide).
52 This suggests  the existence of a vertical link between the provision 
of installation and maintenance of electronic guarding services  to security service 
providers  (upstream) and the sale of such services to end customers  
(downstream).53 
(31) In the first place, this view is strongly supported by some of the Parties’ internal 
documents prepared in the ordinary course of business. For example, one of 
Securitas’ internal document s, referring specifically to the Swedish market, reads: 
[Securitas’ business strategy]. This means that we hav e an [Securitas’ profit 
margin], but at the same time our [Securitas’ business strategy]. Securitas has a 
[Securitas’ profit margin].54 The same internal document indicates that Securitas’ 
[Securitas’ partners information]  and that only in 2020 in Sweden, S ecuritas 
[Securitas’ business strategy] electronic guarding services amounting to SEK […]  
(approx. EUR […]), from [Securitas’ partners information].55 
(32) In the second place, the results of the Commission’s market investigation confirm that sub-contracting is an important element of the security services industry in general. For example, a competitor explains that : “nation-wide presence in the 
Nordic countries is very costly (as the population is small and split in a very large 
geographic area), hence why companies prefer to limit their geographic presence 
and cooperate with other third party competitors in order to offer full geographic 
coverage to their customers who need it. According to [the competitor], this 
                                                 
50  Minutes of a conference call with a customer, dated 15 February 2022, paragraph 7.  
51  Response to question 47.2 of questionnaire Q6 to competitors.  
52  Form CO, paragraph 135.  
53  The Commission notes that for the purposes of this decision, it does not assess a vertical link between 
the provision of manned guarding to third party security service suppliers (upstream) and the provision of manned guarding to end- customers (downstream) . This is because the Notifying Party 
confirms that, there is no such vertical relationship arising as a result of this Transaction. In particular, Stanley Security does not supply manned guarding services to end customers in any capacity, whether directly  or by sub -contracting to a manned guarding company. Instead it advises 
end-customers who wish to procure manned guarding services, to procure those directly from a 
security service provider that is active in this market segment. (Form CO, paragraph 684).  
54  Response of the Notifying Party to Request for Information I -8, Annex Securitas 16(vi)12, Securitas 
Sweden Business Plan for 2021, page 50.  
55  Response of the Notifying Party to Request for Information I -8, Annex Securitas 16(vi)12, Securitas 
Sweden B usiness Plan for 2021, page 51.  
10 partnering is necessary to cover the enormous geography we have in Norway, 
Sweden and Finland.”56  
(33) In the third place, some of the sub-contractors  of installation and maintenance of 
electronic guarding services from  security service providers are able to  supply 
installations and maintenance electronic gua rding services to end customers .57  
(34) Therefore, based on the above, the Commission considers that there exist two tiers 
within the market for the installation and maintenance of electronic guarding equipment, namely between the sub -contracting of the  installation and maintenance 
of electronic guarding services to security service providers  (upstream) in order to 
ensure a fuller product portfolio and better geographic coverage and the sale of 
such services to end customers (downstream).
58 
4.2.4. Conclusion  
(35) The Commission therefore considers that, for the purpose of assessing the present 
case, the provision of manned guarding, alarm monitoring and response, the 
installation and maintenance of electronic guarding equipment and the provision of 
aviation security services to airports and airlines constitute distinct product 
markets. Furthermore the alarm monitoring and response and the installation and 
maintenance of electronic guarding equipment should be further segmented per 
type of customer, namely between resi dential and non-residential  customers.  
4.3. Geographic Market Definition  
4.3.1. The Commission’s  past  decisional practice  
(36) In its past decisional practice, the Commission found that the market for the 
provision of security services  and its  plausible sub-segments  are national in scope , 
due to the existence of specific national regulations and standards, language differences and national preferences deriving  from the reputation of each player at 
national level.
59  
4.3.2. The Notifying Party’s view  
(37) The Parties do not contest th e Commission’s past decisional practice on geographic 
market definition.  
                                                 
56  Minutes of a conference call with a competitor, dated 17 February 2022, paragraph 13.  
57  Form CO, paragraph 165.  
58  The Commission notes that for the purposes of this decision, it does not assess a vertical link between 
the provision of manned guarding to third party security service suppliers (upstream) and the provision of manned guarding to end- customers (downstream). This is because the Notifying Party 
confirms that, there is no such vertical relationship arising as a  result of this Transaction. In 
particular, Stanley Security does not supply manned guarding services to end customers in any capacity, whether directly or by sub -contracting to a manned guarding company. Instead it advises 
end-customers who wish to procur e manned guarding services, to procure those directly from a 
security service provider that is active in this market segment. (Form CO, paragraph 684).  
59  Case M.6292 – Securitas/Niscayah Group, decision of 2 August 2011, paragraphs 16- 18; M.5993 –  
Securi tas/Reliance Security Services/Reliance Security Services Scotland, decision of 
9 November  2010, paragraph 24; and M.4986 – EQT V/Securitas Direct, decision of 
31 January  2008, paragraphs 16- 18. 
11 4.3.3. The Commission’s assessment  
(38) The results of the Commission’s market investigation confirm  that the vast 
majority of security service providers offer their services at national level at most, 
via single or multiple contracts,60 with the exception of certain large security 
service providers, such as the Parties, which also  contract multinational agreements 
with large international customers .61 Moreover, security service providers confirm 
that, within each geographic market, there are no market characteristics that result 
in differentiation of the products and/or services  provided to customers,62 whilst  
their price  levels  are homogeneous in regions across the same country.63  
4.3.4. Conclusion  
(39) The C ommission therefore considers that , for the purpose assessing the present 
case, the market for m anned guardin g, alarm monitoring and response, the 
installation and maintenance of  electronic guarding  equipment and the provision of 
aviation  security services  for airports and airlines , as well as their segmentat ions 
are national in scope. 
5. COMPETITIVE ASSESSMEN T 
5.1. Analytical framework  
(40) Article 2 of the Merger Regulation requires the Commission to examine whether 
notified concentrations are compatible with the inte rnal market, by assessing , 
pursuant to Article s 2(2) and (3), whether they would significantly impede 
effective competition in the internal market or in a substantial part of it, in 
particular as a result of the creation or strengthening of a dominant position.  
5.1.1. Horizontal non-coordinated e ffects  
(41) Horizontal effects are those deriving from a concentration where the undertakings 
concerned are actual or potential competitors of e ach other in one or more of the 
relevant markets concerned. The Commission appraises horizontal effects in 
accordance with the Horizontal Merger Guidelines.64 Horizontal effects may be 
non-coordinated or coordinated.  
(42) As regards horizontal non-coordinated effects, a ccording to paragraph 26 of the 
Horizontal Merger Guidelines, a number of factors  (the list of which is non-
exhaustive ) may be taken into account in order to determine whether significant 
non-coordinated effects are likely to result from a concentration , including the 
combined entity’s market power, closeness of competition and barriers to entry 
and/or expand.  
                                                 
60  Responses to questions 9.1.- 9.3. of q uestionnaire s Q1-Q5 to customers . 
61  Responses to questions 10 -10.4 of questionnaire Q6 to competitors.  
62  ibid.  
63  Responses to questions 8.1.- 8.3. of q uestionnaire s Q1-Q5 to customers . 
64  Guidelines on the assessment of horizontal mergers under the Council Regulation on the control of 
concentrations between undertakings (‘Horizontal Merger Guidelines’), OJ C 31, 5.2.2014. 
12 5.1.2. Vertical effects  
(43) According to the guidance set out in the Non-Horizontal Merger Guidelines ,65 a 
merger between undertakings operating at different levels of the supply chain may 
significantly impede effective competition if such a merger gives rise to 
foreclosure.66 Foreclosure occurs where actual or potential competitors ’ access to 
supplies or markets is hampered or eliminated as a result of the merger, thereby 
reducing those companies ’ ability and/or incentive to compete.67 Such foreclosure 
may also discourage entry or expansion of competitors or encourage their exit.68  
(44) The Non-Horizontal Merger Guidelines identify two forms of foreclosure: input 
and customer foreclosure. Input foreclosure occurs where the merger is likely to 
raise the costs of downstream competitors by restricting their access to an 
important input. Customer foreclosure occurs where the merger is likely to 
foreclose upstream com petitors by restricting their access to a sufficient customer 
base.69 
(45) Pursuant to the Non-Horizontal Merger Guidelines, input foreclosure  arises where, 
post-merger, the new entity would be likely to restrict access to the products or 
services that it would have otherwise supplied absent the merger, thereby raising its 
downstream rivals ’ costs by making it harder for them to obtain supplies of the 
input under similar prices and conditions as absent the merger.70  
(46) In assessing the likelihood of an anticompetitive input foreclosure scenario, the 
Commission examines, first , whether the merged entity would have, post -merger, 
the ability to substantially foreclose access to inputs; second, whether it would have the ince ntive to do so; and third , whether a foreclosure strategy would have a 
significant detrimental effect on competition downstream.
71 
(47) Pursuant to the Non-Horizontal Merger Guidelines, customer foreclosure may occur when a supplier integrates with an important customer in the downstream 
market. As a result of this downstream presence, the merged entity may foreclose access to a sufficient customer base to its actual or potential rivals in the upstream 
market (the input market) and reduce their ability or incenti ve to compete. In turn, 
this may raise downstream rivals ’ costs by making it harder for them to obtain 
supplies of the input under similar prices and conditions as absent the merger. This may allow the merged entity to profitably establish higher prices on the 
downstream market.
72 
(48) In assessing the likelihood of an anticompetitive customer foreclosure scenario, the 
Commission examines, first, whether the merged entity would have the ability to 
foreclose access to downstream markets by reducing its purchases from its 
upstream rivals; second, whether it would have the incentive to reduce its 
purchases upstream; and third , whether a foreclosure strategy would have a 
                                                 
65  Guidelines on the assessment of non- horizontal mergers under the Council Regulation on the control 
of concen trations between undertakings (‘ Non-Horiz ontal Merger Guidelines’ ), OJ C265, 18.10.2008.  
66  Non-Horizontal Merger Guidelines, paragraphs 17 -18.  
67  Non-Horizontal Merger Guidelines, paragraph 18.  
68  Non-Horizontal Merger Guidelines, paragraph 29.  
69  Non-Horizontal Merger Guidelines, paragraph 30.  
70  Non-Horizontal Merger Guidelines, paragraph 3 1. 
71  Non-Horizontal Merger Guidelines, paragraph 32.  
72  Non-Horizontal Merger Guidelines, paragraph 58.  
13 significant detrimental effect on consumers in the downstream market.73 For 
customer foreclosure to be a concern, a vertical merger must involve a company, 
which  is an important customer with a significant degree of market power in the 
downstream market. If, on the contrary, there is a sufficiently large customer base, 
at present or in the future, that is likely to turn to independent suppliers, the Commission is unlikely to raise competition concerns on that ground.
74 
(49) The three conditions for assessing vertical effects are cumulative so that the absence of any of them is sufficient to rule out the likeli hood of anti -competitive 
customer or input foreclosure.
75 
5.1.3. Conglomerate non-coordinated effects  
(50) Conglomerate mergers consist of mergers between companies that are active in 
closely related markets, for instance suppliers of complementary products or of 
products which belong to a range of products that is generally purchased by the 
same set of customers for the same end use.76  
(51) Pursuant to the Non-Horizontal Merger Guidelines, in most circumstances, 
conglomerate mergers do not lead to any competition probl ems.77 However, 
foreclosure effects may arise when the combination of products in related markets 
may confer on the merged entity the ability and incentive to leverage a strong 
market position from one market to another closely related market by means of 
tying or bundling or other exclusionary practices.78  
(52) The Non-Horizontal Merger Guidelines distinguish between bundling, which 
usually refers to the way products are offered and priced by the merged entity and 
tying, which usually refers to situations where c ustomers that purchase one good 
(the tying good) are required to also purchase another good from the producer (the 
tied good).79  
(53) Within bundling practices, a distinction is also made between pure bundling and 
mixed bundling. In the case of pure bundling , the products are only sold jointly in 
fixed proportions. With mixed bundling , the products are also available separately, 
but the sum of the stand-alone prices is higher than the bundled price.80  
(54) The main concern in the context of conglomerate mergers is that of foreclosure. 
The combination of products in related markets may confer on the merged entity 
the ability and incentive to leverage a strong market position from one market to 
another, by means  of tying or bundling or other exclusionary practices. While tying 
and bundling have often no anticompetitive consequences, in certain circumstances 
such practices may lead to a reduction in actual or potential competitors' ability or  
incentive to compete. This may reduce the competitive pressure on the merged 
entity allowing it to increase prices or deteriorate supply conditions in other ways.81  
                                                 
73  Non-Horizontal Merger Guidelines, paragraph 59.  
74  Non-Horizontal Merger Guidelines, paragraph 61.  
75  See Case T –  370/17 KPN BV v European Commission, Judgment  of the General Court of 
23 May  2019, EU:T:2019:354, paragraph 119.  
76  Non-Horizontal Merger Guidelines, para graph 91.  
77  Non-Horizontal Merger Guidelines, para graph 92. 
78  Non-Horizontal Merger Guidelines, paragraph  93. 
79  Non-Horizontal Merger Guidelines, paragraphs  95 -97. 
80  Non-Horizontal Merger Guidelines, para graphs  96. 
81  Non-Horizontal Merger Guidelines, paragraph  93.  
14 (55) In assessing the likelihood of such a scenario, the Commission examines, first , 
whether the merged firm would have the ability to foreclose its rivals,82 second, 
whether it would have the economic incentive to do so83 and, third , whether a  
foreclosure strategy would have a significant detrimental effect on competition, 
thus causing harm to consumers.84 In practice, these factors are often examined 
together as they are closel y intertwined.  
5.2. Assessment   
5.2.1. Introduction  
(56) In the EEA, both Securitas and Stanley Security provide security services mostly  to 
non-residential customers, as well as to residential customers, however, to a much more limited extent .  
(57) Consequently, the T ransaction gives rise the following  horizontal overlaps  and 
non-horizontal links : 
(a) Horizontal overlaps between the Parties’ activities in the provision of alarm 
monitoring and response to non-residential customers in Belgium, Finland, 
Norway, Sweden, the Ne therlands , Denmark, France and Ireland;  
(b) Horizontal overlaps between the Parties’ activities in the provision of alarm monitoring and response to residential customers in Belgium, Sweden, the 
Netherlands and France ; 
(c) Horizontal overlaps between the Parties’ activit ies in the installation and 
maintenance of electronic guarding equipment to non-residential customers 
in Belgium, Finland, Norway, Sweden, the Netherlands, Denmark, France 
and Ireland;   
(d) Horizontal overlaps between the Parties’ activit ies in the inst allation and 
maintenance of electronic guarding equipment to residential customers in 
Belgium, Finland, Norway, Sweden and the Netherlands, Denmark, France and Ireland;  
(e) Vertical links  between the provision of alarm response to third parties 
((upstream) whe re Securitas is active) and the provision of alarm monitoring 
and response services to non-residential end customers ((downstream) where both Parties are active) in Belgium, Finland, Norway, Sweden, the 
Netherlands , Denmark, France and Ireland;   
(f) Vertical links between the sub-contracting of installation and maintenance of 
electronic guarding services ((upstream) where both Parties are active  and the 
sale of such services to non-residential customers ((downstream ), where both 
Securitas and Stanley S ecurity are  active ) in Belgium, Finland, Norway, 
Sweden, the Netherlands, Denmark, France and Ireland; and,  
(g) Conglomerate links between the provision of manned guarding  to end  
customers , of alarm monitoring and response, and of electronic guarding 
services  to non-residential customers in Belgium, Finland, Norway, Sweden, 
the Netherlands , Denmark, France and Ireland.  
                                                 
82  Non-Horizontal M erger Guidelines, paragraphs  95-104. 
83  Non-Horizontal Merger Guidelin es, paragraphs  105- 110. 
84  Non-Horizontal Merger Guidelines, paragraphs  111- 118. 
15 (58) Below the Commission assesses the above -mentioned overlaps with the exception 
of the ones mentioned in paragraph (57)(b)-(d) above : The Transaction does not 
give rise to affected markets  with respect to the horizontal overlaps in alarm 
monitoring and response provided to residential customers ((57)(b)), or the 
horizontal overlaps in the installation and maintenance of electronic guarding 
equipment provided either to non-residential customers ((57)(c)) or to residential 
customers ((57)(d)) and the Commission has not received any complaints from 
market participants in this respect . Similarly , the Commission does not assess the 
horizontal overlaps  and non-horizontal links  arising  in Denmark, France and 
Ireland because they do not give rise to affected markets and beca use t he 
Commission has not received any complaints from market participants in this respect .  
5.2.2. Horizontal Overlaps  
(59) In this Section, the Commission assesses whether the Transaction would give rise 
to serious doubts regarding its compatibility with the internal market as a result of 
the elimination of competiti ve constraints between the Parties in  the market for 
alarm monitoring and response market for non-residential customers in Sweden, Norway, Finland, Belgium and the Netherlands.  
(60) For the reasons detailed below, the Commission finds  that the Transaction does not 
give rise to serious doubts regarding its compatibility with the internal market as a result of the horizontal overlaps in the market for alarm monitoring and response to 
non-residential customers in Sweden, Norway, Finland, Belgium and the 
Netherlands. 
5.2.2.1. Sweden and Norway 
5.2.2.1.1. The Notifying Party’s view  
(61) Table 1 below provides an overview of the  market shares of the Parties and their 
competitors in alarm monitoring and response to non-residential customers in Sweden between 2019-2021, as submitted by the Notifying Party.  
Table 1: Alarm Monitoring and Response to non-resid ential customers in Sweden  
 
Market 
Participant  2019  2020  2021  
Value (MEUR)  Share 
( %) Value (MEUR)  Share 
( %) Value (MEUR)  Share 
( %) 
Securitas  […] [20-30]%  […] [20-30]%  […] [20-30]%  
Stanley  Security  […] [5-10]%  […] [5-10]%  […] [5-10]%  
Combined  […] [20-30]%  […] [20-30]%  […] [20-30]%  
Avarn  […] [10-20]%  […] [10-20]%  […] [10-20]%  
Verisure  […] [10-20]%  […] [10-20]%  […] [10-20]%  
SOS Alarm  […] [5-10]%  […] [5-10]%  […] [5-10]%  
Sector Alarm  […] [0-5]% […] [0-5]% […] [0-5]% 
Te mpest 
Security  […] [0-5]% […] [0-5]% […] [0-5]% 
Rapid  […] [0-5]% […] [0-5]% […] [0-5]% 
Commuter  […] [0-5]% […] [0-5]% […] [0-5]% 
Cubsec  […] [0-5]% […] [0-5]% […] [0-5]% 
Bevakningsgr.  […] [0-5]% […] [0-5]% […] [0-5]% 
Addici  […] [0-5]% […] [0-5]% […] [0-5]% 
16  
Market 
Participant  2019  2020  2021  
Value (MEUR)  Share 
( %) Value (MEUR)  Share 
( %) Value (MEUR)  Share 
( %) 
Vesper  […] [0-5]% […] [0-5]% […] [0-5]% 
Estate  […] [0-5]% […] [0-5]% […] [0-5]% 
Others  […] [20-30]%  […] [20-30]%  […] [20-30]%  
Total  […] 100.0%  […] 100.0%  […] 100.0%  
Source: Parties’ sales data and Securitas’ market size estimates85 
(62) Table 2 below provides an overview of the market shares of the Parties and their 
competitors in alarm monitoring and response to non-residential customers in 
Norway between 2019-2021, as submitted by the Notifying Party.  
Table 2: Alarm Monitoring and Response to non-residential customers in Norway86  
 2019  2020  2021  
Market 
Participant  Value (MEUR)  Sha re  ( %)  Value 
(MEUR)  Sha re  ( %)  Value (MEUR)  Sha re  ( %)  
Securitas  […] [5-10]%  […] [5-10]%  […] [5-10]%  
Stanley  Security  […] [10-20]%  […] [5-10]%  […] [5-10]%  
Combined  […] [20-30]%  […] [10-20]%  […] [10-20]%  
Verisure  […] [10-20]%  […] [10-20]%  […] [10-20]%  
Avarn  […] [10-20]%  […] [10-20]%  […] [10-20]%  
DoroCare  […] [10-20]%  […] [10-20]%  […] [10-20]%  
Sector  Alarm  […] [10-20]%  […] [10-20]%  […] [10-20]%  
KoneAS  […] [5-10]%  […] [5-10]%  […] [5-10]%  
AddSecure  […] [0-5]% […] [0-5]% […] [0-5]% 
Publicfiredep  […] [0-5]% […] [0-5]% […] [0-5]% 
GSS […] [0-5]% […] [0-5]% […] [0-5]% 
Alarm24  […] [0-5]% […] [0-5]% […] [0-5]% 
Others  […] [10-20]%  […] [5-10]%  […] [5-10]%  
Total  […] 100.0%  […] 100.0%  […] 100.0%  
Source: Parties’ sales data and Securitas’  market size estimates87 
(63) The Notifying Party submits that the Transaction would not give rise to 
competition concerns related to the provision of alarm monitoring and response 
services to non-residential customers in Sweden and Norwa y, for a number of 
reasons. In the first place, according to the Notifying Party, the combined entity’s 
market share in Sweden is moderate and does not in itself suggest that the 
                                                 
85  Response of the Notifying Part y to Request for Information I -8, Annex 3.1 – Market Share Norway 
Sweden . 
86  The Commission notes that, although the 2021 market share of the combined entity indicates that 
there is no horizontally affected market in alarm monitoring and response to non -residential 
customers in Norway, the Commission still conducted a competit ive assessment, because of the 
confirmation by two providers, namely Kone AS and DoroCare, that they are not active in this market. Considering the significant market shares allocated by the Notifying Party to these two entities (combined market share of [ 20-30]% in 2021), the Commission concludes that the market 
share of the combined entity in 2021 is in all likelihood exceeding the 20% threshold and therefore treats it as an affected market.  
87  Response of the Notifying Part y to Request for Information I -8, Annex 3.1 – Market Share Norway 
Sweden . 
17 combined entity would have market power.88 In the second place, the Parties are 
not close competitors to one another as they focus on different non-residential 
customer segments. According to the Notifying Party, in Sweden, Securitas focuses 
on a broader range of private customers whilst Stanley Security focuses on public and governmental customers .
89 Likewise in Norway, the Notifying Party submits 
that Securitas’ business opportunities where it competes directly with Stanley 
Security account for less than [20-30]% of Securitas’ entire alarm monitoring .90 In 
the third place, according to the Notifying Party, switching suppliers is e asy91 and 
alarm monitoring is a commoditised service, and therefore, there is no 
differentiation between the service offering of each competitor.92 Finally, the 
Notifying Party submits that  barriers to entry are low ,93 and, that  customers enjoy a 
significant extent of countervailing buyer power.94  
5.2.2.1.2. The Commission’s assessment  
(64) The results of the Commission’s market investigation, as well as the other evidence in the file contradict to a certain extent the Parties’ submissions  as regards the 
combined entity’s market position  post-Transaction and the closeness of 
competition between the Parties. This relates in particular to customers with needs 
for national coverage or with specialised security needs. Moreover, the results of 
the market investigation are inconclusive concerning barriers to entry. In contrast, 
the Notifying Party’ submission appears  to hold true with respect to customers with 
more localized and/or less complex  (standard) security needs. This is for the 
following reasons:  
(65) First, as demonstrated in Table 1 above, the combined entity will, post -Transaction 
be the market leader in the provision of alarm monitoring and response services to non-residential customers in Sweden. More specifically, the Parties estimated the combined market share to be moderate in 2021 a t [20-30]% (combined sales of 
EUR  […]) in Sweden for all non-residential cus tomers, and slightly higher at 
[30-40]% (combined sales of EUR […]) for customers with national coverage 
needs and at [20-30]% (combined sales of EUR […]) for customers with 
specialised security needs in 2021.
95 Moreover, the Notifying Party’s submissions 
suggest that the alarm monitoring and response market to non-residential customers 
in Sweden is fragmented, with a number of other active competitors, including 
Avarn, Verisure, Sector Alarm  etc. 
(66) However, it has been difficult to reach definitive conclusions on the Parties ’ and 
their competitors’ market shares  in Sweden  in the course of the Commission’s 
market investigation. More specifically, t he Parties’ estimates of some competitors’ 
market sales have proven to be inaccurate and at  times over -estimated, including 
                                                 
88  Response of the Notifying Part y to Request for Information I -8, Annex 3.1 – Market Share Norway 
Sweden; Form CO, paragraph 385.  
89  Form CO, paragraph 333 and ff.  
90  Form CO, paragraph 333 and ff.  
91  Form CO , Annex V, Submission on the countervailing  buyer power, dated 1 June 2022, paragraph  33 
and ff.  
92  Response of the Notifying Part y to Request for Information I -8, paragraphs 82 and 327.  
93  Form CO, paragraph 485 and ff.  
94  Form CO, paragraph 644 and Form CO, Annex V, Submission on the countervailing buyer power, 
dated 1 June 2022.  
95  Response of the Notifying Party to Request for Information I -8, Annex 3.1 – Market Share Norway 
Sweden . 
18 for some of the competitors that Securitas considers to compete closely with.96 This 
is also reflected in certain internal documents of Securitas which state that “(…) in 
some solution and services as monitoring we have [60-70] % of the market and 
earn in bottom line more than [market share comparison]  the biggest competitor 
(…)”.97  
(67) The same applies to Norway. More specifically, as demonstrated in Table 2 above, 
the Parties estimate that  the combined entity will, post -Transaction, also be the 
market leader in Norway, with a moderate estimated market share of [10-20]%  
in 2021 for all non-residential customers (combined sales of EUR […]), and higher 
at [30-40]% (combined sales of EUR […]) for customers with national coverage 
needs.98 Similarly to the case of Sweden, the Notifying Party’s submissions suggest 
that the alarm monitoring and response market to non-residential customers in 
Norway  is fragmented, with a number of other active competitors, including Avarn, 
Verisure, Sector Alarm, Tempest Security.  
(68) However, it has also been difficult to reach definitive conclusions on the Parties and their competitors’ market shares in Norway in the c ourse of the Commission’s 
market investigation. In particular, although the Parties’ estimates of competitors’ sales numbers are more accurate compared to those for Sweden, they include 
companies that are not active in the market (such as Doro Care and Kone  AS). In 
the course of the Commission’s market investigation, Doro Care submits that 
“Careium Norge AS (form. Doro Care AS) is delivering Welfare technology, health 
services to Norwegian municipalities. In this marke [t] (Health) Securitas/Stanley 
Security  is not represented. We do not compete in any marke[t]  where 
Securitas/Stanley Security is a competitor ”.
99 Doro Care further explains that it 
“does not offer security services ”100 and that likewise, neither Securitas nor Stanley 
Security are appropriately li cenced to offer welfare technology in Norway, as they 
“have no health personnel in their Alarm Response Centre ”.101  
(69) In the same vein, Kone AS submits that it “ does not offer alarm monitoring 
services which would be relevant ” to this case.102 Kone AS further e xplains  that: 
“[m]ost elevators have an alarm phone system installed, to ensure the safety of 
elevator passengers in case of entrapment and to comply with regulations. This 
alarm phone system enables elevator passengers to establish a 2-way voice 
communication to a call center and report an elevator breakdown. KONE offers its 
customers this 2 -way alarm communication, as well as the on-site maintenance of 
the elevator breakdowns (sending a technician to the elevator) as a service which 
is part of a maintenance agreement between the customer and KONE. (…)To the 
best of [KONE’s] knowledge, Securitas does not offer customers, similar to those 
of KONE (facility management companies, housing owners’ associations, building 
management companies, building owners, etc .), such end-to -end services regarding 
                                                 
96  E-Mails from a competitor to the case team, dated 4, 5 and 6 April 2022; Minutes of call with a 
competitor, dated 5 April 2022.  
97  Response of the Notifying Party to Request for Information I -8, Annex  Securitas 16(vi)10, Securitas 
Sweden Business Plan for  2020, dated 16 September 2019, page 25.  
98  The Commission notes that the Notifying Party failed to provide market shares in alarm monitoring 
and response for non -residential customers with specialised security needs. (Response of the 
Notifying Party to r equest for Information I -8, Annex 3.1 Market Share Norway Sweden).  
99  E-Mail from a competitor to the case team, dated 4 April 2022.  
100  E-Mail from a competitor to the case team, dated 6 April 2022.  
101  ibid.  
102  Response of a competitor to Request for information I -1, dated 6 April 2022, question 4.  
19 responding to and fixing elevator breakdowns. (…) In addition to alarm phone 
systems, KONE provides KONE 24/7 Connected Services which is a value -added 
service for KONE’s maintenance customers based on remote monitori ng, providing 
AI-based predictive maintenance. 24/7 Connected Services are developed fully in-
house (using KONE Employees and subcontractors). KONE 24/7 Connected 
Services is designed to provide information on upcoming maintenance needs and 
identify potent ial issues with the equipment monitored before they arise. (…) To 
conclude: KONE 24/7 Connected Services is primarily a tool for predictive 
maintenance using sensor monitoring, not Alarm Monitoring”.103 
(70) Evidence in the Commission’s file indicates therefore t hat the Parties’ combined 
market position in alarm monitoring and response for non-residential customers  is 
most likely stronger than the Notifying Party estimated in both Sweden and 
Norway. 
(71) Second, the results of the market investigation as well as evidence in the 
Commission’s file  suggest that  the Parties are close competitors , despite the 
presence of  a number of other rival providers  active in the alarm monitoring and 
response market  for non-residential customers in Sweden  and Norway.104  
(72) In the first place, internal documents of Securitas  prepared in the ordinary course of 
business  suggest that the latter considers Stanley Security as one of its five main 
competitors in alarm monitoring  and response to non-residential customers in both 
Sweden and Norway.105 Stanley Security’s internal documents also suggest that 
Securitas is one of its main competitors.106 This is also confirmed by the results of 
the Commission’s market investigation, where  the vast majority of customers 
shares the same view, naming Securitas (and Ava rn) as the closest competitor of 
Stanley Security and Stanley Security (and Avarn) as the closest competitor of 
Securitas in alarm monitoring and response to non-residential customers in both 
Sweden  and Norway.107 
(73) In the second place , the Commission’s market investigation confirms that the 
Parties seem to be some of the few providers that are able to offer alarm monitoring and response to certain types of non-residential customers , namely those with  
(i) specialised and (ii) national c overage needs.
108 The only other security service 
providers that are able to serve this market segment are Avarn, SOS Alarm109 and 
                                                 
103  Response of a competitor to Request for information I -1, dated 6 April 2022, question  1.  
104  Minutes of call with competitor, dated 30 May 2022; Minutes of call wi th competitor dated 
6 April  2022; Minutes of call with competitor, dated 5 April 2022. 
105  Response of the Notifying Party to Request for Information I -8, Annex Securitas 16(vi) 6, Securitas 
Norway Business Plan for 202 1- Remote Services  NO, dated 27 January  2021, slide 2;  Response of 
the Notifying Party to Request for Information I -8, Annex  Securitas 16(vi)7, Securitas Norway 
Business Plan for 2022-  SOC and Remote Services, dated 27 September 2021, slide 3.  
106  Response of the Notifying Party to Request for Information I -8, Annex Stanley 16(vi)50, Swinmark 
Business Performance, dated December 2017, slide 3.  
107  Response to questions 14.1 and 14.2 of questionnaire Q1 to Customers in Sweden; Response to 
questions 14.1 and 14.2 of questionnaire Q2 to Customers i n Norway.  
108  A competitor in Norway submits that “ There is none other than Securitas, Avarn or Stanley Security 
which can offer a professional SOC to the FG3 marked/customers  [i.e. lowest level of classification 
of alarm systems installed at the premises of customers with specialised needs in Norway] ” 
(Response of a competitor to question 3 of Questions to Electronic Guarding providers in Norway, dated 25 May 2022).  
109  Minutes of a conference call with a competitor, dated 5 April 2022, paragraphs 4 and 10.  
20 potentially Securitas Direct  (that is owned by Verisure)110 in Sweden, and Avarn in 
Norway. In contra st, a number of alarm monitori ng and response providers, such as 
Verisure and Sector Alarm, focus primarily on residential customers and on non-
residential customers with standard security needs and do not or cannot offer alarm 
monitoring and response services to non-residential custom ers with specialised 
security needs.111  
(74) Third , the combined entity will continue to face  strong competitive pressure by a 
sufficient number of alternative providers serving non-residential customers with 
standard security needs in both Sweden and Norway. More specifically, the results 
of the Commission’s market investigation confirm that a number of credible 
alternatives to the combined entity, with strong market presence, are able and will 
continue to be able to serve non-residential customers with standard security needs 
in Sweden and Norway. These include, among others, Avarn, Verisure and Sector 
Alarm  both in Sweden and in Norway and Tempest Security and SOS Alarm in 
Sweden .112 These entities are well established players that are currently competing 
closely with the Parties in alarm monitoring and response for non-residential customers with s tandard security needs, and that, according to the Notifying Party’s 
estimates, held collectively ~ [40-50]% (Sweden) and ~ [40-50]% (Norway) of the 
alarm monitoring and response to non-residential customers’ market in 2021. More 
concretely, according to the  Parties, Avarn’s market shares are [10-20]% (Sweden) 
and [10-20]% (Norway); Verisure’s market shares are [10-20]% (Sweden) and 
[10-20]% (Norway); Sector Alarm’s market share in Norway is [10-20]% and SOS 
Alarm’s market share in Sweden is [5-10]%.  
(75) However , the same conclusion cannot be reached for non-residential customers 
with specialised and national coverage needs. When it comes to these types of non-
residential customers, the Commission’s market investigation suggests that certain 
companies, such as Ve risure and Sector Alarm, do not compete with the P arties, 
and thus, the number of credible alternatives to the combined entity are limited to 
Avarn, SOS Alarm and potentially Securitas Direct (that is owned by Verisure) in 
Sweden ,
113 and Avarn in Norway.  
(76) In this context, the Commission notes  that Avarn, the stronger competitor of the 
Parties in the Nordics, confirms that customers can switch to other suppliers, 
“because there are many other companies that can offer the same in all 
countries ”.114 However, Avarn  confirms that the options are more limited for 
customers with specialised security needs.115 Nevertheless, the combined entity 
                                                 
110  Information gathered from Securitas Direct website in Sweden suggest that it is able to offer alarm 
monitoring and response services to large customers as well as customers with national coverage needs: “Securitas Direct’s team for clients with natio nwide representation specialises in corporations 
that are represented nationwide. (…) Who is regarded a major client? In general, retail chains and large companies or organisations who operate all over Sweden or the Nordic countries are regarded as major c lients ”. (Securitas Direct website, available at: https://www.securitasdirect.se/en , last 
accessed 30 June 2022).  
111  Minutes of a conference call with a competitor, dated 4 April 2022, paragraph 4; Minutes of a conference call with a competitor, dated 6 A pril 2022, paragraph 3 and ff.  
112  Responses to questions 10- 10.2 of questionnaire Q1 to customers in Sweden; Responses to 
questions  10-10.2 to questionnaire Q2 to competitors in Norway.  
113  Minutes of a conference call with a competitor, dated 5 April 2022, paragraphs 4 and 10; Minutes of a 
conference call with a competitor, dated 4 April 2022, paragraph 4; Minutes of a conference call with a competitor, dated 6 April 2022, paragraph 3 and ff.  
114  Response to question 30 of questionnaire Q6 to competitors.  
115  Response to question 30.1 of questionnaire Q6 to competitors.  
21 will continue to face strong competitive pressure by Avarn in both Sweden and 
Norway. 
(77) Fourth, the responses  to the Commission’s market investigation are mixed  and 
inconclusive116 with regard to barriers to entry in the alarm monitoring and 
response market  for non-residential customers in Sweden and Norway.  
(78) In the first place, the  majority of competitors submit s that barriers to entry are 
moderate in the sense that, although the respondents acknowledge that barriers to 
entry exist, new entrants are still able to enter the market .117 However, a competitor 
explains that: “although it is not difficult for a small secur ity company to enter the 
market, it will most likely only sell to small businesses with local presence”.118 
(79) In the second place, competitors mention that  entry costs  are high, especially for 
new entrants who lack a sufficient customer base , and mention the existence  of 
“strict and specific regulatory requirements ”119 of operating an ARC in Sweden 
and Norway.120 Nevertheless, the Commission notes that the entry costs indicated 
by certain competitors (on average EUR 4.5 million)121 are relatively low 
compared to the  overall market size of alarm monitoring and response to non-
residential customers in Sweden and Norway, which is estimated by the Parties to be approximately EUR […] for Sweden and EUR […] for Norway (or EUR […] 
without DoroCare  and KoneAS),
122taking into account scale efficiencies as well as 
the presumption that the lifetime of an ARC  is long, following its creation.   
(80) In the third place , although entry in Sweden and Norway has been limited in the 
last three years,123 the Commission notes that there has been some recent entry in 
the past three years  by Certego in Norway and Sweden and by Coor in 2020 in 
Sweden .124 It has not been possible, nonetheless, to determine the market share  
these players  captured since their  entry.  
(81) Nevertheless , despite these considerations around the Parties’ market position, the 
closeness of competition between them and the existence of certa in barriers to 
entry, the Commission’s market investigation as well as evidence from the 
Commission’s file indicate that the Transaction  is not likely to lead to an 
impediment of effective competition in the alarm monitoring and response markets 
to non-residential customers in Sweden and Norway. As shown above, the 
combined entity’s combined market share is moderate and the combined entity will 
continue to face strong competitive pressure by a sufficient number of alternative 
providers serving non-residential customers with standard security needs in both 
Sweden and Norway. 
(82) While the combined entity will face competition from fewer credible competitors 
with regard to non-residential customers with specialised and national coverage 
                                                 
116  Response to questions 24 and 24.1 of Questionnaire Q6 to competitors.  
117  Response to question 24 of Questionnaire Q6 to competitors. 
118  Minutes of a conference call with a competitor, dated 17 February 2022, paragraph 20.  
119  Response to question 24.1 of Questionnaire Q6 to competitors. 
120  Minutes of a conference call with a competitor, dated 30 May 2022, paragraph 8.  
121  Response to quest ion 24.1 of Questionnaire Q6 to competitors. 
122  Response of the Notifying Party to Request for Information I -8, Annex 3.1, Market Share Norway 
Sweden.  
123  Response to questions 19 and 19.1- 19.6 of Questionnaire Q6 to competitors.  
124  Response to questions 19 and 19.1- 19.6 of Questionnaire Q6 to competitors; Minutes of a conference 
call with a competitor, dated 1 July 2022, paragraph 3.  
22 security needs , the market investigation as well as evidence from the Commission’s 
file show that these are normally large companies that enjoy a significant degree of 
countervailing buyer power when purchasing alarm monitoring and response 
services.  
(83) First, alarm monitoring an d response  accounts for a small proportion of customer’s 
total spend on security services, even for customers with specialised security 
needs.125 Thus, the  incentive of the combined entity to deteriorate the commercial 
terms of alarm  monitoring in order to increase its profits to the detriment of its 
customer relations is limite d. For instance, the Parties submit that, in 2021:  
(a) in Sweden,126 on average, alarm monitoring and response  services accounted 
for [5-10]% of the overall spend of Securitas’ and [10-20]% of Stanley 
Security’s  largest customers;127 whilst,  
(b) in Norway,128 on averag e, alarm monitoring and response services accounted 
for [0-5]% of the overall spend of Securitas’ and [5-10]% of Stanley 
Security’s l argest customers.  
(84) These figures indicate that  customers can rely on their spend on other security 
services in their contract negotiations in alarm monitoring and response and, for 
instance, threaten to reduce or generally limit the purchasing of other security 
services from the Parties if the Parties  deteriorate the supply conditions in alarm 
monitoring and response. 
(85) Second, the non-residential customers with national coverage and specialised needs are generally large , sophisticated companies  that are  experienced purchasers, 
relying on tender procedures or other advanced negotiating procedures to select 
security providers.  
(86) Third , the vast majority of customers in Sweden who participated in the market 
investigation did not express concerns about the Transaction, some of them explicitly acknowledging the ir buyer power.
129 For example, a customer in Sweden 
explains that “ if the suppliers decide to raise their prices, [the customer]  considers 
that they would still hold some buyer power considering they are a large  
customer ”.130 The same applies to Norway . In pa rticular, the vast majority of 
customers in Norway who participated in the market investigation did not express concerns about the Transaction.
131 For instance, a respondent submits: “ (…) These 
                                                 
125  Form CO, Annex V, Submission on the countervailing buyer power, dated 1 June 2022, focusses 
primarily on alarm monitoring. However, the arguments are equally applicable to customers of alarm 
monitoring and response should the Commission consider such a hypothetical product market  (Form 
CO, Annex V, Submission on the countervailing buyer power, dated 1 June 2022, footnote 3) .  
126  Form CO, Annex V, Submission on the countervailing buyer power, dated 1 June 2022, paragraph 27.  
127  According to the Notifying Party, largest customers by revenue refer to customers that (i) spent at least EUR 50,000 per year on either of the Parties’ services, and (ii) procured alarm monitoring from Securitas or Stanley Security respectively. ( Form CO, Annex V, Submission on the countervailing 
buyer power, dat ed 1 June 2022, paragraph 18) . 
128  Form CO, Annex V, Submission on the countervailing buyer power, dated 1 June 2022, paragraph  18. 
129  Response to questions 26.1, 26.1.1 and 26.1.2 of Questionnaire Q1 to customers in Sweden; Minutes of a conference call with a customer dated 29 April 2022, paragraph 14; Minutes of a conference call with a c ustomer dated 4 May 2022, paragraph 15; Minutes of a conference call with a customer dated 
25 May 2022, paragraphs 9 and 10; Minutes of a conference call with a customer dated 16 February  2022, paragraphs 11- 13. 
130  Minutes of a conference call with a custo mer dated 25 May 2022, paragraphs 9 and 10.  
131  Response to questions 26.1, 26.1.1 and 26.1.2 of Questionnaire Q2 to customers in Norway.  
23 services are also provided by other competitors in the market like AVARN. The 
operation should therefore have no impact in these markets ”.132 
(87) Fourth, some of the large customers have the option to self-supply or partially self-
supply alarm  monitoring , at a lower cost compared to the costs of launching a 
certified ARC by an entrant in the alarm monitoring and response market . In this 
context, the Commission’s market investigation confirms that  there is no need for 
the customers  to obtain a n EN 50518 certification that is a requirement  for the 
ARCs of security service providers  offering alarm monitoring and response .133 
Furthermore , Securitas submits  that it contracts alarm response to customers who 
self-supply alarm monitoring134 and, conversely, that it does not differentiate its 
prices for alarm response based on whether the request comes from Securitas’ 
alarm monitoring customers or from customers doing in-house alarm 
monitoring.135 However, the Commission notes that its market investigation 
revealed that companies that own an ARC might still rely on security service providers for their staffing.
136 For instance, a customer mentions that it “ rel[ies] on 
the security service provider to deliver highly trained operators with good 
knowledge of our facilities that will operate the ARC 24/7 with a high service 
standard according to the service level agreement we have with the supplier ”.137  
(88) Moreover, Securitas submits that approximately [50-60]% of its top 100 largest 
customers (by overall revenue) in Sweden have opted to self-supply alarm monito ring services either partially  or fully,
138 arguing that self -supply is a valid 
option, particularly for larg e and medium size organisations.139 In this context, 
Securitas indicates one customer with specialised security and national coverage 
needs that switched to self -supplying alarm monitoring a nd response between 2019  
and 2021, namely  Norwegian customer […].140  
(89) Fifth , alarm monitoring and response customers who responded in the 
Commission’s market investigation suggest that in Sweden, the barriers to switching are medium high and therefore, switching providers is relatively 
common .
141 Although respondents submit that “ switching security service can be 
                                                 
132  ibid.  
133  Form CO, paragraph 1000 and ff; Response of the Notifying Party to Request for Information I -10, 
paragraph 7 and ff; Response of a customer to a Request for Information (on self -supplying) of 
1 July 2022, questions 3- 4.  
134  Response of the Notifying Party to Request f or Information I -10, paragraph 1.  
135  Response of the Notifying Party to Request f or Informa tion I -10, paragraph 15.  
136  Minutes of a conference call with a competitor, dated 1 July 2022, paragraph  8.  
137  Response of a customer to a Request for Information (on self -supplying) of 1 July 2022, question 5.  
138  According to the Parties’ submission, partial self -supply refers to instances where customers: (i) use 
ARC staff supplied by security companies, (ii) outsource alarm monitoring for some of their sites 
(applicable to multi -site customers that self -supply alarm monitoring to its main site 
(i.e., headquarters), or (iii) outsource some alarm monitoring services (e.g., fire alarm monitoring). (Response of the Notifying Party to Request for Information I -10, paragraph 17 and ff).  
139  As regards Stanley Security, it does not have any customers with in- house ARCs, buying alarm 
response services, as Stanley Security does not in -source manned guarding for alarm response and 
thus encourages customers to contract directly with a manned guarding specialist, as this will avoid the customer paying a mark -up on the response services and will also avoid Stanley Security having 
responsibility for delays in alarm response . (Response of the Notifying Party to Request for 
Information I -10, paragraph  3).  
140  Form CO, Annex V, Submission on the countervailing buyer pow er, dated 1 June 2022, 
paragraph s 39-40.  
141  On average, Swedish customers marked barriers to switching as medium/neutral, scoring 2.67/5. (Response to question 16.1 of questionnaire Q1 to customers in Sweden).  
24 an administrative burden and can therefore be costly even if the price is lower than 
the price the existing provider offers ”142 and that one “(…) w ould need to train the 
new service provider to get to know [the customer’s]  systems which requires 
resources ”143, no Swedish customer strongly contests its ability to switch provider 
if necessary.144 A customer with multinational presence explains that, “ speak ing 
only for [the customer], the [T]ransaction is unlikely to chan [g]e the status quo 
given [the customer’s] procurement strategy for security services (…) and our 
existing agreements with Securitas”,  confirming that large customers with 
specialised and na tional coverage needs might indeed have less choice, but also a 
sufficient degree of buyer power.145 
(90) Finally, customers in Sweden and Norway express neutral to positive views with 
regard to the T ransaction.146 For instance, a customer in Norway believes that, so 
long as Avarn exercises competitive pressure on the combined entity, the 
Transaction should not have any impact in the alarm monitoring and response 
market  for non-residential customers .147 Additionally, a customer in Sweden 
submits that “[e] ven if the parties do have some overlaps, the merger seems logic 
as the “new” Securitas can provide the full range of services needed. So, we deem it as positive from a product quality and service range perspective but find it more 
unclear if efficiencies will have p ositive impact on price levels. It’s negative for the 
security market as such as a competitor vanish.”
148 
5.2.2.1.3. Conclusion  
(91) In light of the above, the Commission concludes that the Transaction does not give 
rise to serious doubts regarding its compatibility with t he internal market as a result 
of the horizontal overlaps  in the market for alarm monitoring and response to non-
residential customers in Sweden and Norway post-Transaction, in particular 
because of the fact that the combined entity’s market shares are moderate, the existence of a number of credible alternatives for non-residential customers with 
standard security needs, and the countervailing buyer power of non-residential 
customers with specialised and/or national coverage needs.  
5.2.2.2. Finland  
5.2.2.2.1. The Notifying Pa rty’s view  
(92) Table 3 below provides an overview of the market shares of the Parties and their 
competitors in alarm monitoring and response to non-residential c ustomers in 
Finland between 2018-2020, as submitted by the Notifying Party.
149  
                                                 
142  Response to question 16.2.1 of questionna ire Q1 to customers  in Sweden.  
143  ibid. 
144  ibid. 
145  Response to question 26.1 of questionnaire Q4 to competitors in the Netherlands.  
146  Response to question 26.1 of questionnaire Q1 to customers in Sweden; Response to question  26.1 of 
questionnaire Q2 to customers in Norway.  
147  Response to question 26.1.1 of questionnaire Q2 to customers in Norway.  
148  Response to question 26.1.1 of questionnaire Q1 to customers in Sweden.  
149  The Notifying Party did not submit 2021 data, except for Sweden and Norway.  
25 Table 3: Alarm Monitoring and Response to non-residential customers in Finland  
 
Market 
Participant  2018  2019  2020  
Value (MEUR)  Share 
( %) Value (MEUR)  Share 
( %) Value (MEUR)  Share 
( %) 
Securitas  […] [20-30]%  […] [20-30]%  […] [20-30]%  
Stanley  Security  […] [0-5]% […] [0-5]% […] [0-5]% 
Combined  […] [20-30]%  […] [20-30]%  […] [20-30]%  
Avarn  […] [10-20]%  […] [10-20]%  […] [10-20]%  
Sector Alarm  […] [0-5]% […] [0-5]% […] [5-10]%  
Verisure  […] [0-5]% […] [0-5]% […] [0-5]% 
SOL  […] [0-5]% […] [0-5]% […] [0-5]% 
ISS Palvelut Oy  […] [0-5]% […] [0-5]% […] [0-5]% 
Palmia  […] [0-5]% […] [0-5]% […] [0-5]% 
K2 […] [0-5]% […] [0-5]% […] [0-5]% 
Vantti  […] [0-5]% […] [0-5]% […] [0-5]% 
Others  […] [40-50]%  […] [30-40]%  […] [30-40]%  
Total  […] 100.0%  […] 100.0%  […] 100.0%  
Source: Parties’ sales data and Securitas’ market size estimates150 
(93) The Notifying Party submits that the Transaction would not give rise to 
competition concerns related to the provision of alarm monitoring and response 
services  to non-residential customers in Finland. This is because, according to the 
Notifying Party, (i) the Parties face competition from a large number of small and 
large players;151 (ii) the Parties are not close competitors to one another as they 
focus on different non-residential customer segments;152 (iii) the combined entity  
will continue to face competitive constraints post -Transaction due to the prevalence 
of sub-contracting of response services and the ability of smaller rivals to expand 
their alarm monitoring and response services;153 and (iv) certain large non-
residential customers have in-house  ARC s and can therefore credibly threaten to 
take these services in -house.154 
5.2.2.2.2. The Commission’s assessment  
(94) The results of the Commission’s market investigation, as well as the other evidence in the file, confirm  the Parties’ submissions as regards the combined entity’s 
market position post -Transaction and the closeness of competition between the  
Parties and barriers to entry. The results of the market investigation regarding 
barriers to entry and expansion are inconclusive. This is for the following reasons:  
(95) First, as demonstrated in Table 3 above, the combined entity will, post -Transaction 
be the market leader in the provisi on of alarm monitoring and response services to 
non-residential customers in Finland . More specifically, the Parties estimated the 
combined market share to be moderate in 2020 at [20-30]% (combined sales of 
EUR  […]) in Finland  for all non-residential customers, and slightly higher at 
                                                 
150  Form CO , Annex 7.1, Parties’ market share. 
151  Form CO, paragraph 515.  
152  Form CO, paragraph 516.  
153  Form CO, paragraph 517.  
154  Form CO, paragraph 518.  
26 [30-40]% (combined sales of EUR […])155 for customers with national coverage 
needs in 2020.156  
(96) Second, the market share increment caused by the Transaction in alarm monitoring 
and response for non-residential customers in Finland is small, ranging 
between  […]% between 2018-2020. This low increment demonstrates that Stanley 
Security’s activity is very limi ted in Finland , its sales amounting to less than 
EUR  […] annually in 2018-2020, compared to Securitas’ turnover of around 
EUR  […] annually in 2018-2020.  
(97) Third , post -Transaction, the Parties will continue to face competition from one 
large player, Avarn (ma rket share of [10-20]% in alarm monitoring and response to 
non-residential customers in Finland in 2020), and several smaller players (including Sector Ala rm, Verisure, SOL, ISS Palvelut  Oy, Palmia, K2, and Vantti). 
The Commission notes that Avarn, who is the stronger competitor of the Parties in the Nordics, confirms that customers can switch to other suppliers, “ because there 
are many other companies that can offer the same in all countries ”.
157 
(98) Fourth, the results of the market investigation confirm the Parties’ view that they 
are likely not close competitors  in the alarm monitoring and response market for 
non-residential customers  in Finland. More specifically, the vast majority of 
customers name Avarn as Securitas’ closest competitor, with a  small minority also 
naming AddSecure.158 Notably, no customer names Stanley Security as Securitas’ 
closest competitor.159 In the same vein, the vast majority of competitors names 
Avarn as Securitas’ closest competitor, with limited references to Verisure and 
Stanley Security.160 In addition, Securitas focuses on tenders where customers 
require alarm monitoring and response alongside other manned guarding services (e.g. on-site guarding or mobile patrol) whereby Stanley Security’s would have a 
larger share of cus tomers that seek alarm monitoring and response alongside 
electronic guarding services.
161 However, both customers162 and competitors163 
name Securitas  and Avarn, at the same rate, as the closest competitors of Stanley 
Security.  
(99) Fifth , the responses to the Commi ssion’s market investigation are mixed and 
inconclusive164 concerning barriers to entry in the alarm monitoring and response 
market  for non-residential customers in Finland.  
(100) In the first place, the  majority of competitors submit that barriers to entry are 
moderate, in the sense  that, although certain regulatory and cost barriers exist, new 
entrants  are still able to enter the market .165 
                                                 
155  Form CO, paragraph 520 and Table 6.64.  
156  The Parties fail to provide their and their competitors’ market shares for alarm monitoring and 
response to non -residential customers with specialised security needs in Finland.  
157  Response to question 30 of questionnaire Q6 to competitors.  
158  Response to question 14 of questionnaire Q3 to Customers in Finland .  
159  ibid.  
160  Response to question 15.1.2 of questionnaire Q6 to Competitors.  
161  Form CO, paragraph 509.  
162  Response to question 15.1.2 of questionnaire Q6 to Competitors.  
163  Response to question 15.2.1 of questionnaire Q6 to Competitors.  
164  Response to questions 24 and 24.1 of Questionnaire Q6 to competitors.  
165  Response to question 24 of Questionnaire Q6 to competitors. 
27 (101) In the second place, competitors mention that entry costs are high.166 Nevertheless, 
the Commission notes that, the entry costs indicated by certain competitors (on 
average EUR 4.5 million)167 are relatively low compared to the overall market size 
of alarm monitoring and response to non-residential customers in Finland, which i s 
estimated by the Parties to be approximately EUR […],168 taking into account scale 
efficiencies as well as the presumption that the lifetime of an ARC is long,  
following its creation.  
(102) In the same vein, entry in Finland has been limited in the last three years .169 
However , the Commission notes that despite the barriers, the results of its market 
investigation suggest that there has been some recent entry in the past three years in the Finnish market , e.g. by Certego.
170 It has not been possible, nonetheless, to 
determine the market share  that Certego captured since its entry.  
(103) Sixth , customers in Finland  express neutral to positive views with regard to the 
Transaction.171 More importantly, virtually all customers in Finland who responded 
to the Commission’s market investigation agree that there are enough credible 
alternatives that will exert competitive pressure to the combined entity.172 This is 
confirmed by a competitor of the Parties in Finland, who explains that customers can “ switch suppliers and based on their procurement strategy either go with one 
or multiple suppliers .”
173 Furthermore , some customers also argue that there will be 
benefits  as a result of the Transaction, such as the improvement of the combined 
entity’s product offering. In this context, a customer submits that the Transaction 
will result in “ stronger service capabilities for Securitas, but still choices for 
procuring from different companies ”.174 
5.2.2.2.3. Conclusion  
(104) In light of the above, the Commission concludes that the Transaction does not give 
rise to serious doubts regarding its compatibility with the internal market as a result of the horizontal overlap in the market for alarm m onitoring and response to non-
residential customers Finland  post-Transaction, in particular because of the fact 
that the combined entity’s market share is moderate, the increment brought by the 
Transaction is negligible , and the Parties are likely not clos e competitors . 
5.2.2.3. Belgium and the Netherlands  
5.2.2.3.1. The Notifying Party’s view  
(105) Table 4 below provides an overview of the market shares of the Parties and their 
competitors in alarm monitoring and response to non-residential customers in 
Belgium between 2018-2020, as submitted by the Notifying Party.
175  
                                                 
166  Minutes of a conference call with a competitor, dated 30 May 2022, paragraph 8.  
167  Response to question 24.1 of Questi onnaire Q6 to competitors. 
168  Form CO, Annex 7.1, Parties’ market share.  
169  Response to questions 19 and 19.1- 19.6 of Questionnaire Q6 to competitors.  
170  Response to questions 19 and 19.1- 19.6 of questionnaire Q6 to competitors.  
171  Response to question 2 6.1 of questionnaire Q3 to customers in Finland.  
172  Response to question 26.1.1 of questionnaire Q3 to customers in Finland.  
173  Response to question 47.2 of questionnaire Q6 to competitors.  
174  Response to question 26.1.1 of questionnaire Q3 to customers in Finland.  
175  The Notifying Party did not submit 2021 data, except for Sweden and Norway.  
28 Table 4: Alarm Monitoring and Response to non-residential customers in Belgium  
 
Market 
Participant  2018  2019  2020  
Value (MEUR)  Share 
( %) Value (MEUR)  Share 
( %) Value (MEUR)  Share 
( %) 
Securitas  […] [10-20]%  […] [10-20]%  […] [10-20]%  
Stanley  Security  […] [10-20]%  […] [10-20]%  […] [10-20]%  
Combined  […] [20-30]%  […] [30-40]%  […] [20-30]%  
Johnson 
Controls  […] [10-20]%  […] [10-20]%  […] [10-20]%  
G4S […] [10-20]%  […] [10-20]%  […] [10-20]%  
Seris  […] [5-10]%  […] [5-10]%  […] [5-10]%  
SMC  […] [5-10]%  […] [5-10]%  […] [5-10]% 
NIT 
Technologies  […] [5-10]%  […] [0-5]% […] [0-5]% 
Verisure  […] [0-5]% […] [5-10]%  […] [5-10]%  
Praxis group  […] [0-5]% […] [0-5]% […] [0-5]% 
No mos  […] [0-5]% […] [0-5]% […] [0-5]% 
Others  […] [5-10]%  […] [5-10]%  […] [5-10]%  
Total  […] 100.0%  […] 100.0%  […] 100.0%  
Source: Parties’ sales data and Securitas’ market size estimates176 
(106) Table 5 below provides an overview of the market shares of the Parties and their 
competitors in alarm monitoring and response to non-residential customers in the 
Nethe rlands  between 2018-2020, as submitted by the Notifying Party.  
Table 5: Alarm Monitoring and Response to non-residential customers in the 
Netherlands 
 
Market 
Participant  2018  2019  2020  
Value (MEUR)  Share 
( %) Value (MEUR)  Share 
( %) Value (MEUR)  Share 
( %) 
Securitas  […] [20-30]%  […] [20-30]%  […] [20-30]%  
Stanley  Security  […] [0-5]% […] [0-5]% […] [0-5]% 
Combined  […] [20-30]%  […] [20-30]%  […] [20-30]%  
G4S […] [10-20]%  […] [10-20]%  […] [10-20]%  
Trigion  […] [10-20]%  […] [10-20]%  […] [10-20]%  
SMC  […] [0-5]% […] [0-5]% […] [0-5]% 
NVD  […] [0-5]% […] [0-5]% […] [0-5]% 
Cruon  […] [0-5]% […] [0-5]% […] [0-5]% 
Seris  […] [0-5]% […] [0-5]% […] [0-5]% 
Randstad  […] [0-5]% […] [0-5]% […] [0-5]% 
Intergarde  […] [0-5]% […] [0-5]% […] [0-5]% 
Schipper  […] [0-5]% […] [0-5]% […] [0-5]% 
Europac  […] [0-5]% […] [0-5]% […] [0-5]% 
MPL  […] [0-5]% […] [0-5]% […] [0-5]% 
Alarm Meldnet  […] [0-5]% […] [0-5]% […] [0-5]% 
RouteIT  […] [0-5]% […] [0-5]% […] [0-5]% 
Verisure  […] [0-5]% […] [0-5]% […] [0-5]% 
Others  […] [20-30]%  […] [20-30]%  […] [5-10]%  
Total  […] 100.0%  […] 100.0%  […] 100.0%  
Source: Parties’ sales data and Securitas’ market size estimates177 
                                                 
176  Form CO , Annex 7.1, Parties’ market share. 
177  Form CO , Annex 7.1, Parties’ market share. 
29 (107) The Notifying Party submits that the Transaction would not give rise to 
competition concerns related to the provision of alarm monitoring and response 
services  to non-residential customers in Belgium . This is because, according to the 
Notifying Party, (i) post-Transaction, the Parties will continue to face strong 
competition from well established players  (e.g. G4S, Johnson Controls, Seris and 
Verisure);178(ii) the Parties are not close competitors to one another as they focus 
on different non-residential cust omer segments  (i.e. Stanley Security services 
several customers in the retail segment whereas Securitas focuses on public and 
specialised security customers );179 (iii) the Parties are facing out -of-market 
competition by non-integrated suppliers of elec tronic  guarding services 
(e.g., Siemens, Bosch) that also  compete for alarm monitoring and response 
contracts of large corporate customers  with specialised and/or national coverage 
needs, where alarm monitoring forms a part  of requested security services;180 
(iv) barriers to entry and/or expansion are low;181 (iv) switching suppliers is 
easy;182 and (v) it is common for large non-residential customers  in Belgium to  
have in-house ARC s and can therefore credibly threaten to take these services in-
house.183 
(108) Likewise in  the Netherlands , the Notifying Party submits that (i) the increment 
brought about by the Transaction is small;184 (ii) there are 34 licensed ARCs  
providing monitoring services in the Netherlands, some of which exert and will 
continue to exert competitive pressure on the combined entity post -Transaction 
(e.g. Allied Universal/G4S, Trigon and Verisure through its brand Securitas 
Direct );185 (iii) the Parties are not close competitors, as Stanley Security services 
customers with national coverage needs in the ret ail segment, whereas Securitas 
achieves the majority of its revenues from larg e and/or medium -size customers;186 
and (iv) barriers to entry and/or expand are low.187  
5.2.2.3.2. The Commission’s assessment  
(109) The results of the Commission’s market investigation, as well as the other evidence 
in the file, confirm the Parties’ submissions as regards the combined entity’s 
market position post -Transaction and the closeness of competition between the 
Parties and barriers to entry. The results of the market investigation regarding barriers to entry and expansion are inconclusive. This is for the following reasons:  
(110) First, as demonstrated in Table 4 above, the combined entity will, post -
Transacti on, be the market leader in the provision of alarm monitoring and 
                                                 
178 Form CO, paragraph 497.  
179  Form CO, paragraphs 491 and 499.  
180  According to the Notifying Party, t hese suppliers participate in tenders for bundled security services 
and sub-contract alarm monitoring and response to third parties. The Notifying Party give s the 
example of  Siem ens winning  a contr act with NATO and sub -contracting  alarm monitoring to a third 
party  provider, as it does not operate an ARC . In this context, the Notifying Party submits that non -
integrated suppliers of electronic guarding services have a very good knowledge of alarm monitoring 
and response services offered by various providers and can easily switch between these providers . 
(Form CO, paragraph 492).  
181  Form CO, paragraph 498.  
182  Form CO, paragraph 500.  
183  Form CO, paragraph 201.  
184  Form CO, paragraph 522.  
185  Form CO, paragraphs 523- 525 and 530.  
186  Form CO, paragraph 526.  
187  Form CO, paragraph 531.  
30 response services to non-residential customers in Belgium. More specifically, the 
Parties estimated the combined market sh are to be moderate in 2020 at [20-30]%  
(combined sales of EUR […]) in Belgium  for all non-residential customers,188 and 
slightly higher  at [30-40]% (combined sales of EUR […])189 for non-residential 
customers with national coverage needs  in 2020.190 The same applies to the 
Netherlands  as demonstrated in Table 5 above , where the Parties estimated the 
combined market share to be moderate in 2020 a t [20-30]% (combined sales of 
EUR  […])191 in the Netherlands for all non-residential customers, and slightly 
higher at [20-30]%  (combined sales of EUR […])192 for non-residential customers 
with national coverage needs in 2020.193  
(111) Second, post -Transaction, the Parties will continue to face  strong  competition from 
a number of players in Belgium , including Johnson Controls (holding a market 
share of ~ [10-20]% in 2020), G4S (~ [10-20]%), Seris (~ [5-10]%), Verisure 
(~[5-10]%), and SMC  ([5-10]%) and in the Netherlands, including G4S ( [10-20]%) 
and Trigion ([10-20]%), as demonstrated in Tabl e 4 and Table 5 above. 
(112) However, it has  also been difficult to reach definitive conclusions on the P arties 
and their competitors’ market shares in the Netherlands . More specifically, the 
Parties’ estimates of some competitors’ market sales are likely to be inaccurate at times, for example, by considering Randstad as a competitor to the Parties, when in 
fact it is a human resource consulting firm, and to the Commission’s knowledge, it 
does not offer security services.  
(113) Third , in the Netherlands, the market share increment caused by the Transaction in 
alarm monitoring and response for non-residential customers is small , ranging 
between […]% between 2018-2020. This low increment demonstrates that Stanley 
Security’s activity is very limited in the Ne therlands , where it achieved a turnover 
of only around EUR […] annually in 2018-2020, compared to  Securitas’ turnover 
of more than EUR […] annually in 2018-2020.  
(114) Fourth, the results of the market investigation confirm the Parties’ view that they 
are likely  not close competitors in the alarm monitoring and response market for 
non-residential customers in Belgium and the Netherlands, and that the Parties face a number of  other credible alternatives . More specifically, for Belgium, the vast 
majority of custome rs name s G4S and Seris  as Securitas’ closest competitor, with a 
small minority briefly naming a number of other providers, such as Verisure and 
Stanley Security, at the same negligible rate .
194 In the same vein, the vast majority 
of competitors names Verisure and Jonson Controls  as Stanley Security’s  closest 
competitor, with limited references to Securitas , G4S and Seris .195 Customers 
confirm that a number of competitors are able to offer alarm monitoring and 
response services to non-residential customers with national coverage and/or 
specialised security needs. For instance, one states that “ Seris, G4S and Securitas 
                                                 
188  Form CO , Annex 7.1, Parties’ market share. 
189  Form CO, Table 6.61.  
190  The Parties fail to provide their and their competitors’ market shares for alarm monitoring and 
response to non -residential customers with specialised security needs in Belgium . 
191  Form CO , Annex 7.1, Parties’ market share. 
192  Form CO , Table 6.68.  
193  The P arties fail to provide their and their competitors’ market shares for alarm monitoring and 
response to non -residential customers with specialised security needs in the Netherlands .  
194  Response to question 14 of questionnaire Q5 to customers in Belgium.  
195  Response to question 15.1.2 of questionnaire Q6 to competitors.  
31 are the only security company able to offer integrated services throughout all 
Belgium for large companies .”196 For the Netherlands, the vast majority of 
competitors names  G4S and Trigion as both Securitas and Stanley Security’s 
closest competitors,197 whilst competitors consider in addition to those, SMC as the 
closest competitor to both Securitas and Stanley Security.198 A competitor in 
Belgium co nfirms that it considers “ Stanley [Security] more as the technical 
installer and Securitas as the Service provider ”.199 
(115) Fifth , the responses to the Commission’s market investigation are mixed and 
inconclusive200 concerning barriers to entry in the alarm monitoring and response 
market  for non-residential customers in Belgium and the Netherlands.  
(116) In the first place, the  majority of competitors submit that barriers to entry are high;  
however, new entrants  are still able to enter the market .201 
(117) In the second place, competitors mention that entry costs are high.202 Nevertheless, 
the Commission notes that the entry costs indicated by certain competitors (on 
average EUR 4.5 million)203 are relatively low compared to the overall market size 
of alarm monitoring and response to non-residential customers in Belgium and the 
Netherlands, which is estimated by the Parties to be approximately EUR […] and 
EUR […] respectively .204 
(118) Sixth , customers i n Belgium and the Netherlands  express neutral to positive views 
with regard to the T ransaction.205 Moreover, certain customers in the Netherlands 
expect an improvement in the quality of services offered by the combined entity as a result of the Transaction, whilst other believe that, even in the case of price 
increases, switching remains possible against reasonable  migration costs.
206 
Likewise, some customers in Belgium believe that, the combined entity could “ be 
more efficient and provide lower prices ”, that “a structured challenger on the 
market is positive for price vs. quality in the total market” and that there is “(…) possibly more room for innovation” as a result of the Transaction.
207  
                                                 
196  Response to question 14.1 of questionnaire Q5 to customers in Belgium.  
197  Response to question 14 of questionnaire Q4 to customers in the Netherlands.  
198  Response to questions 15.1.2 and 15.2.1. to questionnaire Q6 to competitors.  
199  Response to question 15.4 of questionnaire Q6 to competitors.  
200  Response to questions 24 and 24.1 of Questionnaire Q6 to competitors.  
201  Response to question 24 of Questionnaire Q6 to competitors. 
202  Minutes of a conference call with a competitor, dated 30 May 2022, paragraph 8.  
203  Response to question 24.1 of q uestionnaire Q6 to competitors.  
204  Form CO, Annex 7.1, Parties’ market share.  
205  Response to question 26.1 of questionnaire Q4 to customers i n the Netherlands; and, Response to 
question 26.1 of questionnaire Q5 to customers in Belgium.  
206  Response to question 26.1 of questionnaire Q4 to customers in the Netherlands.  
207  Response to question 26.1 of questionnaire Q5 to customers in Belgium.  
32 5.2.2.3.3. Conclusion  
(119) In light of the above, the Commission concludes that the Transaction does not give 
rise to serious doubts regarding its compatibility with the internal market as a result 
of the horizontal overlaps in the market for alarm monitoring and response to non-
reside ntial customers in Belgium and the Netherlands post -Transaction, in 
particular because of the fact that the combined entity’s market shares are 
moderate, and in the Netherlands, the Transaction leads to a small increment only, 
the Parties are likely not cl ose competitors and a number of other credible 
alternative providers are active in both the Belgian and the Dutch markets . 
5.2.2.4. Conclusion  
(120) In light of the above, the Commission concludes that the Transaction does not give rise to serious doubts regarding its c ompatibility with the internal market as a result 
of the horizontal overlaps in the market for alarm monitoring and response to non-
residential customers in Sweden, Norway, Finland, Belgium and the Netherlands  
post-Transaction. 
5.2.3. Vertical Links  
5.2.3.1. Input Foreclosure  
(121) In this Section, the Commission assesses whether the Transaction would result in input foreclosure of the combined entity’s rivals in the downstream market for 
alarm monitoring and response, if Securitas limits access to its alarm response 
services u pstream  in Sweden, Norway, Finland, Belgium and the Netherlands .  
(122) This is because, evidence in the Commission’s file suggests that a number of players active in the market for the provision of alarm monitoring and response, 
including among others, SOS Alarm, Verisure and Sector Alarm, do not provide 
alarm response  servic es themselves , but instead, subcontract this service from third 
party providers.
208 
5.2.3.1.1. The Notifying Party’s view  
(123) Table 6 below provides an overview of the market shares of Securitas and its 
competitors in the upstream market for the provision of alarm response services to third party providers in Sweden in 2020, as submitted by the Notifying Party.  
Table 6: Sales Shares of Alarm Response services to third party providers in Sweden  
Supplier  Sales  shares (% per value)209 
Securitas  [30-40]% 
Stanley Security  [0-5]% 
Combined   [30-40]% 
Avarn  [20-30]%  
                                                 
208  Minutes of a conference call with a competitor dated 5 April 2022, paragraph 5; Minutes of a 
conference call with a competitor dated 16 February 2022, paragraph 9; Minutes of a conference call with a competitor dated 5 April 2022, paragraph 3.  
209  The Noti fying Party did not submit 2021 sales data. However, the Notifying Party confirms that 
neither Securitas’ nor its competitors’ sale shares in Sweden for 2021 are materially different from those for 2020. (Response of the Notifying Party to Request for Infor ma tio n I -13). The Notifying 
Party did not submit information on the overall value of alarm response services sold to third party security services providers in 2020 in Sweden either. 
33 Supplier  Sales  shares (% per value)209 
Tempest Secuirty  [5-10]%  
Rapid Säkerhet AB  [5-10]%  
Commuter Security 
Group AB  [5-10]%  
Cubsec AB  [0-5]% 
Addicci Security AB  [0-5]% 
Others  [10-20]%  
Total  100%  
Source: Securitas’  sales data210 
(124) Table 7 below provides an overview of the market shares of Securitas and its 
competitors in the upstream market for the provision of alarm response services to 
third party providers in Norway in 2020, as submitted by the Notifying Party.  
Table 7: Sales Shares of Alarm Response services to third party providers in Norway  
Supplier  Sales  shares (% per value)211 
Securitas  [20-30]%  
Stanley Security  [0-5]% 
Combined  [20-30]%  
Avarn  [50-60]%  
Others  [10-20]%  
Total  100%  
Source: Securitas’  sales data212 
(125) Table 8 below provides an overview of the market shares of Securitas and its 
competitors in the upstream market for the provision of alarm response services to 
third party providers in Finland in 2020, as submitted by the Notifying Party.  
Table 8: Sales Shares of Alarm Response services to third party providers in Finland 
Supplier  Sales  shares (% per value)213 
Securitas  [20-30]%  
Stanley Security  [0-5]% 
Combined  [20-30]%  
Avarn  [30-40]% 
SS Palvelut Oy  [0-5]% 
Vantti & other listed 
competitors  [30-40]%  
Total  100%  
Source: Securitas’  sales data214 
                                                 
210  Response of the Notifying Party to Request for information I -2, Table  1.3.1. 
211  The Notifying Party did not submit 2021 sales data. However, the Notifying Party confirms that 
neither Securitas’ nor its competitors’ sale shares in Norway for 2021 are materially different from those for 2020. (Response of the Notifying Party to Request for Information I -13). The Notifying 
Party did not submit information on the overall value of alarm response services sold to third party security services providers in 2020 in Norway either. 
212  Response of the Notifying Party to Request for inf ormation I -2, Table 1.5.1. 
213  The Notifying Party did not submit 2021 sales data. However, the Notifying Party confirms that neither Securitas’ nor its competitors’ sale shares in Finland for 2021 are materially different from those for 2020. (Response of the Notifying Party to Request for Information I -13). The Notifying 
Party did not submit information on the overall value of alarm response services sold to third party security services providers in 2020 in Finland either.  
214  Response of the Notifying Par ty to Request for information I -2, Table 1.4. 
34 (126) Table 9 below provides an overview of the market shares of Securitas and its 
competitors in the upstream market for the provision of alarm response services to 
third party providers  in Belgium in  2020, as submitted by the Notifying Party.  
Table 9: Sales Shares of Alarm Response services to third party providers in Belgium  
Supplier  Sales  shares (% per value)215 
Securitas  [5-10]%  
Stanley Security  [0-5]% 
Combined  [5-10]%  
Seris  [50-60]%  
Vi gicore  [20-30]%  
G4S [5-10]%  
Total  100%  
Source: Securitas ’ sales data216 
(127) Table 10 below provides an overv iew of the market shares of Securitas and its 
competitors in the upstream market for the provision of alarm response services to 
third party providers  in the Netherlands in 2020, as submitted by the Notifying 
Party.  
Table 10: Sales Shares of Alarm Response services to third party providers in the 
Netherlands 
Supplier  Sales  shares (% per value)217 
Securitas  [0-5]% 
Stanley Security  [0-5]% 
Combined  [0-5]% 
G4S [30-40]%  
Trigion  [10-20]%  
Cruon  [5-10]%  
Seris  [5-10]%  
NVD  [5-10]%  
Randstad  [0-5]% 
Intergarde  [0-5]% 
Schipper  [0-5]% 
Others  [10-20]%  
Total  100%  
Source: Securitas’  sales data218 
(128) The Notifying Party submits that  alarm response  (which it considers as a segment 
of manned guarding) and alarm monitoring and response  (see market shares in 
Table 1, Table 2, Table 3, Table 4, Table 5 above) are not vertically related 
                                                 
215  The Notifying Party did not submit 2021 sales data. However, the Notifying Party confirms that 
neither Securitas’ nor its competitors’ sale shares in Belgium for 2021 are materially different from those for 2020. (Response of the Notifying Party to Request for Information I -13). The Notifying 
Party did not submit information on the overall value of alarm response services sold to third party security services providers in 2020 in Belgium either.  
216  Response of the Notifying Party to Request for information I -2, Table 1.1. 
217  The Notifying Party did not submit 2021 sales data. However, the Notifying Party confirms that neither Securitas’ nor its competitors’ sale shares in the Netherlands for 2021 are materiall y different 
from those for 2020. (Response of the Notifying Party to Request for Information I -13). The 
Notifying Party did not submit information on the overall value of alarm response services sold to third party security services providers in 2020 in th e Netherlands either.  
218  Response of the Notifying Party to Request for information I -2, Table 1.2. 
35 markets , because the  former is not an ‘input’ to the latter, and that instead, alarm 
monitoring and alarm response are  complementary security services which are 
generally pick ed and chosen by end customers depending on their  security needs  
(i.e. some may purchase only monitoring as an end-service and do not require any 
response).219  
(129) In any event, the N otifying Party submits that the combined entity would neithe r 
have the ability nor the incentive to foreclose input, because: (i) a number of 
credible alarm response providers are active in Sweden, Finland, Norway, Belgium 
and the Netherlands;220 (ii) the volume of alarm response service s that Securitas 
provides to other security companies (excluding Stanley Security) is limited and 
could be readily replaced by competitors ;221 (iii) t he service offered by Securitas is 
not materially different from that offered by its competitors;222 (iv) changing 
supplier of manned guardi ng/response is a simple process that does not require 
significant effort nor time;223 (v) S ecuritas’ rivals will have the  ability to expand 
output if the combined entity forecloses input and capacity constraints  can be 
overcome over a relatively short period of time  (i.e. it only takes several weeks to 
train a guard and there are no substantial investments requi red for providing this 
training );224 and (vi) the additional  downstream margin generated by any diversion 
of end customers to the combined entity’s downstream  offering will be  insufficient 
to compensate for the margin that would be lost upstream from ceasing the supply 
of alarm response  services to security companies.225 
5.2.3.1.2. The Commission’s assessment  
5.2.3.1.2.1. Ability to Foreclose Input  
(130) As regards the combined entity’s ability  and potentially incentive  to engage in 
input foreclosure to the detriment of alarm monitoring and response providers in Sweden, Finland, Norway, Belgium and the Netherlands, the Commission notes the 
following.
226 
(131) First, contrary to the Parties’ vie ws, the majority of the respondents to the 
Commission’s market investigation considers  alarm response as an important input 
to the provision of alarm monitoring and response, one of which explains that 
                                                 
219  Form CO, Annex II, Additional Considerations on Vertical Relationships, dated 25 May 2022, 
paragraph 3.  
220  Form CO, Annex II, Additional Considerations on Vertical Relationships, dated 25 May 2022,  
paragraph 9 and Table 9.  
221  Form CO, Annex II, Additional Considerations on Vertical Relationships, dated 25 May 2022,  
paragraph 10.  
222  Form CO, Annex II, Additional Considerations on Vertical Relationships, dated 25 May 2022, paragraph 18.  
223  ibid.  
224  Form CO, Annex II, Additional Considerations on Vertical Relationships, dated 25 May 2022, paragraph 19.  
225  Form CO, Annex II, Additional Considerations on Vertical Relationships, dated 25 May 2022, paragraph 22.  
226  The Commission provides a competitive assessment of the geographic markets  listed in Tables 6 
to 10, even where they do not give rise to affected markets, as certain responses in the market 
investigation prompted the Commission to assess these verti cal relationships as to their effect on the 
mar ke t . 
36 “having access to dispatching manned guards is essenti al for the execution of 
alarm response to verify alarm cause and take further needed action ”.227 
(132) Second, the Commission’s market investigation confirms the Parties’ argument 
that, in all five geographic markets, there exists at least one credible alternative  to 
Securitas, to whom downstream rivals can switch to, should the merged entity 
foreclose s input post -Transaction.228  
(133) In the first place , respondents to the Commission’s market investigation name 
(i) Avarn in Sweden; (ii) 4T -Turva Oy in Finland; (iii) Avarn and local companies 
such as Team Security, First Security Group, Safe24, Alltid24, RST, Tynset Vaktselskap, Manngard, Alarmeksperten, Norvakt Kirkenes, Toma Security, 
Hønefoss Vaktselskap, Snøhetta, NVC in Norway; (iv) G4S and Seri s in Belgium; 
and (v) Sleutelwacht, Intergarde  and G4S  in the Netherlands.
229  
(134) In the second place, the results of the Commission’s market investigation suggest 
that there are to an extent barriers to switching providers, however, some 
respondents confirm th at they could switch to alternative credible providers.230  
(135) Third , despite the fact that, in certain geographic markets, the Commission’s 
market investigation suggests the existence of only one credible alternative (e.g. in the case of Norway and Sweden, a c ompetitor explains that “ the only companies 
that offer National Alarm Response Services in Norway and Sweden are: Securitas and Avarn”
231), Securitas estimates that the volume of alarm response service s that 
it provides to other security companies (excluding Stanley Security) is limited and 
could be readily replaced by competitors .232 More specificall y, the Notifying Party 
submits the following.233  
(a) In Sweden in 2020, response service s that Securitas provides to other security 
companies (excluding Stanley Security) represent ed revenues of 
approximately EUR […], a small amount relative to the value of response 
services consumed by end customers  (i.e. EUR […] according to the 
Notifying Pa rty’s estimates , excluding the value of response services to end-
customers offered by Stanley Security with Securitas  as a sub -contractor).  
(b) In Norway in 2020, response services that Securitas provides to other security 
companies (excluding Stanley Securit y) represent revenues of approximately 
EUR […], a small amount relative to the value of response services 
consumed by end customers (i.e. EUR […] according to the Notifying 
Party’s estimates , excluding the value of response services to end-customers 
offere d by Stanley Security with Securitas as a sub-contractor).  
(c) In Finland in 2020, response service s that Securitas provides to other security 
companies (excluding Stanley Security) represent revenues of approximately 
EUR […], a small amount relative to the value  of response services 
consumed by end customers  (i.e. EUR […] according to the Notifying 
                                                 
227  Responses to questions 4, 4.1 and 4.2 of Questionnaire Q7 to B2B competitors. 
228  Responses to questions 5.1 of Questionnaire Q7 to B2B competitors.  
229  ibid.  
230  Responses to questions 14 -14.2 of Questionnaire Q7 to B2B competitors. 
231  Response to question 4.2 of Questionnaire Q7 to B2B Competitors.  
232  Form CO, Annex II, Additional Considerations on Vertical Relationships, dated 25 May 2022, 
paragraph 10.  
233  ibid.  
37 Party’s estimates , excluding the value of response services to end-customers 
offered by Stanley Security with Securitas as a sub-contractor).  
(d) In Belgium  in 2020, response service s that Securitas provides to other 
security companies (excluding Stanley Security) represent revenues of 
approximately EUR […], a negligible amount relative to the value  of 
response services consumed by end customers  (i.e. EUR […] according to 
the Notifying Party’s estimates , excluding the value of response services to 
end-customers offered by Stanley Security with Securitas as a sub-contractor).  
(e) In the Netherlands  in 2020, response service s that Securitas provides to other 
securi ty companies (excluding Stanley Security) represent revenues of 
approximately EUR […], a negligible amount relative to the value  of 
response services consumed by end customers  (i.e. EUR […] according to 
the Notifying Party’s estimates , excluding the value of response services to 
end-customers offered by Stanley Security with Securitas as a sub-
contractor).  
(136) According to the above -mentioned data submitted by Securitas , security service 
providers arguably do not rely largely on Securitas’ alarm response servi ces in 
order to supply this service to end customers . This could be the case, on the one 
hand because , there exist other integrated  third party security service providers 
(e.g. Avarn, Seris, G4S, Tempest Security etc.) that offer alarm response to end-
customers via their  in-house capabilities whilst, on the other hand, non-integrated 
alarm monitoring and response providers do not only rely on Securitas when  
procuring alarm response from other third party providers. Finally, considering the 
small volumes of alarm response that Securitas provides to other security service providers, alternative suppliers will  likely not need to increase their capacity 
significantly  in order to cover all or part of the needs , should the combined entity 
engage  in input foreclosure strategies  post -Transaction.
234  
(137) Fourth, Securitas is already , pre-Transaction, active in both the upstream and 
downstream markets, and has not engaged in any foreclosure strategies to date.235 
This is confirmed by the majority of respondents to the Commission’s market 
investigation that purchase alarm response services from Securitas . These 
respondents  consider that there will be negative consequences for non- integrated 
third party alarm monitoring and response providers , if the combined entity decide s 
to stop providing alarm response services to them, or provide them at a higher 
price .236 However, the fact that Securitas is already pre -Transaction active in both 
upstream and downstream markets, whilst Stanley Security is not active upstream, 
suggests t hat the combined entity will most likely have neither the ability nor the 
incentive to engage in input foreclosure strategies.237 Accordingly, none of the 
respondents to the Commission’s market investigation express substantiated input 
foreclosure concerns  in any of the geographically affected markets , with the 
exception of one competitor in Sweden. This competitor, that does not currently 
purchase alarm response services from Securitas in Sweden, submits that there 
                                                 
234  ibid, paragraph 11.  
235  Form  CO, Annex II, Additional Considerations on Vertical Relationships, dated 25 May 2022, 
paragraph 26.  
236  Response to question 13 of Questionnaire Q7 to B2B Competitors. 
237  In this context, a respondent indicates that “ Stanley [Security]  does not provide ma nned guarding  [for 
alarm response] , thus we do not expect  the situation to change after [T] ransaction”.  (Response to 
questions 10 -10.3 of Questionnaire Q7 to B2B Competitors).  
38 have been occasions where Securitas reduced  the quality of its services (e.g. by 
delaying alarm response) to end customers that c ontracted a  third party provider for 
the alarm monitoring, and Securitas for the alarm response.238 However, the 
competitor does  not provide concret e evidence to support its claim. In contrast , 
another competitor purchasing alarm response services from Securitas  in Sweden  
submits “ with the information currently available, [the competitor] does not see 
any incentive for Securitas to stop providing manned guarding services f or alarm 
response to us or to provide them at a higher cost / worse conditions in any of the 
countries mentioned. (…) Obviously if any of those impacts would be likely to take 
place, that would imply a clear detrimental effect of the planned merger on [the  
competitor] and other competitors (…)” .239 However, in view of the lack of the 
combined entity’s ability to engage in input foreclosure strategies, no further analysis of the combined entity’s incentive to foreclose input will be conducted for the purposes of this decision.  
5.2.3.1.3. Conclusion  
(138) In light of the above, the Commission concludes that the Transaction does not give 
rise to serious doubts regarding its compatibility with the internal market because  
of input foreclosure, due to the lack of ability  of the combined entity to foreclose  
access to  alarm response  in Sweden, Finland, Norway, Belgium and the 
Netherlands . 
5.2.3.2. Customer Foreclosure  
(139) In this Section, the Commission assesses whether the Transaction would result in 
customer foreclosure of the combined entity’s rivals in the market for the provision 
of alarm response , if the combined entity  limits access to its alarm monitoring 
services downstream.  
5.2.3.2.1. The Notifying Party’s view  
(140) Table 11 below provides an overview of the Parties’ purchasing shares of alarm 
response services from third party providers in Sweden in 2021.  
Table 11: Purchasing Shares of Alarm Response services from third party providers in 
Sweden in 2021  
Supplier  Purchasing shares (% per 
value)240 
Securitas  [0-5]% 
Stanley Security  [5-10]%  
Combined  [5-10]%  
Avarn  [20-30]%  
Bevakning  [0-5]% 
Addici  [0-5]% 
Vesper  [0-5]% 
                                                 
238  Minutes of a conference call with a competitor, dated 30 May 2022, paragraph  13.  
239  Response to questions 10 – 10.3 of Questionnaire Q7 to B2B Competitors. 
240  The Notifying Party does not provide information on the overall value of alarm response services 
purchased by security services providers in 2021 in Sweden.  
39 Supplier  Purchasing shares (% per 
value)240 
Commuter  [0-5]% 
Rapid  [0-5]% 
Te mpest  [0-5]% 
Cubsec  [0-5]% 
Estate  [0-5]% 
Others  [50-60]%  
Total  100%  
Source: Parties’ purchasing data241 
(141) Table 12 below provides an overview of the Parties’ purchasing shares of alarm 
response services from third party providers in Norway in 2021.  
Table 12: Purchasing Shares of Al arm Response services from third party providers in 
Norway in 2021 
Supplier  Purchasing shares (% per 
value)242 
Securitas  [0-5]% 
Stanley Security  [10-20]%  
Combined  [10-20]%  
AddSecure  [5-10]%  
Verisure  [20-30]%  
Avarn  [0-5]% 
Sector  [10-20]%  
Others  [30-40]%  
Total  100%  
Source: Parties’ purchasing data243 
(142) Table 13 below provides an overview of the Parties’ purchasing shares of alarm 
response services from third party providers in Finland in 2021.  
Table 13: Purchasing Shares of Alarm Response services from third party providers in 
Finland in 2021  
Supplier  Purchasing shares (% per 
value)244 
Securitas  [20-30]%  
Stanley Security  [5-10]%  
Combined  [30-40]%  
Verisure  [20-30]%  
ISS Palvelut Oy  [10-20]%  
Avarn  [20-30]%  
Total  100%  
Source: Parties’ purchasing data245 
(143) Table 14 below provides an overview of the Parties’ purchasing shares of alarm 
response services from third party providers in Belgium in 2021.  
                                                 
241  Response of the Notifying Party to Request for Information I -12, Table 4.6.  
242  The Notifying Party does not provide information on the overall value of alarm response services 
purchased by security services providers in 2021 in Norway.  
243  Response of the  Notifying Party to Request for Information I -12, Table 4.7.  
244  The Notifying Party does not provide information on the overall value of alarm response services purchased by security services providers in 2021 in Finland.  
245  Response of the Notifying Par ty to Request for Information I -12, Table 4.8.  
40 Table 14: Purchasing Shares of Alarm Response services from third party providers in 
Belgium in 2021 
Supplier  Purchasing shares (% per 
value)246 
Securitas  [0-5]% 
Stanley Security  [10-20]%  
Combined  [10-20]%  
G4S [20-30]%  
Seris  [10-20]%  
Others  [50-60]%  
Source: Parties’ purchasing data247 
(144) Table 15 below provides an overview of the Parties’ purchasing shares of alarm 
response services from third party providers in the Netherlands in 2021.  
Table 15: Purchasing Sha res of Alarm Response services from third party providers in 
the Netherlands in 2021  
Supplier  Purchasing shares (% per value)248 
Securitas  [40-50]%  
Stanley Security  [0-5]% 
Combined  [40-50]%  
G4S [20-30]%  
Trigion  [20-30]%  
Cruon  [0-5]% 
Seris  [0-5]% 
NVD  [0-5]% 
Randstad  [0-5]% 
Intergarde  [0-5]% 
Schipper  [0-5]% 
Total  100%  
Source: Parties’ purchasing data249 
(145) Although the Notifying Party does not consider alarm response and alarm 
monitoring to be vertically related markets,250 it submits that, the combined entity 
will not have the ability to engage in customer forec losure strategies, because: 
(i) Securitas already pre -Transaction does not purchase  alarm response services (as 
it is a fully integrated player)251; whilst (ii) Stanley Security already pre -
Transact ion relied heavily on Securitas  for the provision of alarm response services 
in Sweden, Norway, Finland, Belgium and the Netherlands.252  
                                                 
246  The Notifying Party does not provide information on the overall value of alarm response services 
purchased by security services providers in 2021 in Belgium.  
247  Response of the Notifying Party to Request for Information I -12, Table 4.9.  
248  The Notifying Party does not provide information on the overall value of alarm response services purchased by security services providers in 2021 in the Netherlands.  
249  Respon se of the Notifying Party to Request for Information I -12, Table 4.10.  
250  Form CO, Annex II, Additional Considerations on Vertical Relationships, dated 25 May 2022, paragraph 3.  
251  Form CO, paragraph 153 and Table 6.1.  
252  Form CO, paragraph 156 and Table  6.2.  
41 5.2.3.2.2. The Commission’s Assessment  
5.2.3.2.2.1. Ability to Foreclose Customers  
(146) As regards the combined entity’s ability to engage in custome r foreclosure to the 
detriment of alarm response providers in Sweden, Norway , Finland, Belgium and 
the Netherlands, the Commission notes the following.253 
(147) First, the impact on the competitive status quo pre -Transaction will be very limited 
for the reasons de monstrated below.  
(148) In the first place, Securitas has already , pre-Transaction, been a vertically 
integrated entity with strong alarm response presence in all of the above -mentioned 
geographic markets. Therefore, already pre -Transaction, Securitas does not 
purchase  alarm response from third party providers, with the exception of Finland 
and the Netherlands  and to a very small extent , Norway , where a negligible 
percentage (below [0-5]% of its alarm response revenue in 2020 in all instances) of 
Securitas’ alarm response revenues originates from subcontracting the service from 
rival third party providers.254  
(149) In the second place, even though in Finland and the Netherlands , Securitas sub-
contracts some of its alarm response needs from third party providers as 
demonstrated in Table 11 and Table 15 above  (indicating that Securitas’ purchas ing 
share of alarm response services amounts to ~ [30-40]% and ~ [40-50]% of the 
overall purchases of alarm response services from third party providers in 2021), it 
would not be able to engage in customer foreclose strategies as a result of the 
Transaction, as Stanley Security is not vertically integrated, and therefore does not 
offer alarm response services in-house.  
(150) In the third place, Stanley Security m ay not provide alarm response services in-
house pre -Transaction, but it sources the vast majority of it s needs from Securitas 
in Sweden, Norway and Finland (between […]% of its alarm response revenue in 2020) already .
255 In the case of Belgium, Stanley Security does not procure any 
alarm response services from Securitas.256 However, even if it were to switch to 
Securitas post -Transaction, this would unlikely have an effect on any of the 
combined entity’s alarm response competitors in Belgium. This is because, Stanley 
Security’s revenues only represent a small fragment of the  alarm response market 
for non-residential customers in Belgium (EUR […], representing [0-5]% of the 
overall market  in 2020).257 In the Netherlands, the Parties’ submis sions suggest that  
all of Stanley Security’s alarm monitoring and response revenues to non-residential 
customers originate from the provision of alarm monitoring services only, and that therefore, Stanley Security did not offer alarm response services in between 2018-
2020.
258 
                                                 
253  The Commission provides a competitive assessment of the geographic markets  listed in Tables 11 
to 15, even where they do not give rise to affected markets, as certain responses in the market 
investigation prompted the Commission to assess these v ertical relationships as to their effect on the 
mar ke t . 
254  Form CO, Table 6.1.  
255  Form CO, Table 6.2.  
256  ibid.  
257  Form CO, Annex 7.1, Parties’ market shares.  
258  ibid.  
42 (151) Second, none of the respondents to the Commission’s market investigation raised 
customer foreclosure concerns based on the Parties’ conduct pre -Transaction, with 
the exception of a competitor in Sweden.259 The competitor is concerned that 
Stanley Security, which pre -Transaction offers advanced alarm monitoring as an 
independent  non-integrated provider, will post -Transaction hinder its competitors’ 
expansion by only cooperating with Securitas for the provision of alarm response to customers with national coverage needs.
260 In this context, the competitor 
explains that pre -Transacti on, smaller alarm response providers that do not offer 
national coverage rely on Stanley Security, who outsources alarm response services 
to them.261 More specifically, pre -Transaction, customers of Stanley Security with 
national coverage needs were offered the option to multi -source alarm response for 
their different sites in Sweden, based on their needs. For instance, customers would 
have the option of contracting smaller and cheaper alarm response providers in 
metropolitan areas where more alarm response providers are active and Securitas in 
more remote areas where no alternative providers are active. The competitor is concerned that, post -Transaction, the combined entity would offer national 
coverage for alarm response and would otherwise refuse to offer i ts alarm response 
services in remote areas where it will be the only provider, unless it is awarded the 
full contract.
262 This way, the combined entity could prevent customers from multi -
sourcing alarm response services and consequently, eliminate smaller competitors 
from the alarm monitoring and response market.  
(152) However, the Commission notes that  even if the combined entity engages into 
customer foreclosure strategies post -Transaction, the effects on competition would 
be limited, for the following reasons . 
(a) The competitive status quo would not alter significantly. In the case of 
Sweden, Stanley Security’s captive demand for alarm response for non-
residential customers is only [0-5]% of its overall alarm response needs, as it 
sources the remaining [90-100]% from Securitas,263 as mentioned in 
paragraph (150) above . Therefore, even if the combined entity were to 
engage in customer foreclosure strategies, these strategies wou ld not have a 
material effect on Securitas’ upstream alarm response competitors, 
considering that, already pre -Transaction, Stanley Security purchases a 
negligible amount of its alarm response needs from them ;  
(b) Alarm response, from a supply- side perspective, requires the same resources 
(i.e. security personnel, vehicles etc.) as manned guarding.264 According to 
the Notifying Party’s submission, the market for manned guarding is significantly larger than the one for alarm response. More specifically , in the 
case of Sweden, the Notifying Party estimates the overall manned guarding market in 2020 at EUR […], which is significantly larger than its estimate of 
the alarm response to non-re sidential customers, at EUR  […]. Furthermore, 
the vast majority of t he respondents to the Commission’s market 
investigation believe s that barriers to entry in the manned guarding market 
                                                 
259  Minutes of a conference call with a competitor dated 30 May 2022.  
260  The competitor explains: “(…) The problems arise with agreements with national coverage that are 
not divided. A state actor that has 98% of its agreement in a big city but has 1 office in a place where 
only Securitas is available. Is it then reasonable that onl y Securitas can bid on the 98%?” (Response 
to question 35.1 of Questionnaire Q6 to Competitors).  
261  Minutes of a conference call with a competitor dated 30 May 2022, paragraph 8 and et seq.  
262  Minutes of a conference call with a competitor dated 30 May 20 22, paragraph 10.  
263  Form CO, Table 6.2.  
264  Form CO, paragraph 193.  
43 are low.265 In this vein, alarm response providers will still have other manned 
guarding opportunities available  and their compet itiveness in terms of scale is 
unlikely to be affected by customer foreclosure strategies .  
(153) Nonetheless, in view of the lack of the combined entity’s ability to engage in 
customer foreclosure strategies, no further analysis of the effects on competition, 
should the c ombined entity foreclose customers , will be conducted for the purposes 
of this decision.  
(154) Third , the competitive landscape in all of the above -mentioned geographic markets 
suggests that the combined entity will face competition in the downstream market 
for alarm  monitoring and response by a number of providers that are not vertically 
integrated  (and therefore  would still need to sub -contract alarm response from third 
party providers), and therefore, should the combined entity engage in customer 
foreclosure strategies, a sufficient number of alternative downstream providers will 
remain available . More specifically , the Notifying Party lists between 3 -5 non-
integrated credible alternative alarm monitoring and response providers in each of 
the relevant geographic markets  for non-residential customers (including SOS 
Alarm, Verisure and Securitas Direct, Sector Alarm, Alarm 24, Prosero, Johnson Controls Chubb/APi etc.), depending on the geographic region.
266 
5.2.3.2.3. Conclusion  
(155) In light of the above, the Commission c oncludes that the Transaction does not give 
rise to serious doubts regarding its compatibility with the internal market as a result 
of customer foreclosure, due to the lack of ability  of the combined entity to 
foreclose access to a sufficient customer base  in alarm response  in Sweden, 
Finland, Norway, Belgium and the Netherlands . 
5.2.3.3. Foreclosure in electronic guarding  
(156) In this Section, the Commission assesses whether the Transaction would result in customer foreclosure
267 of the combined entity’s rivals in the ma rket for the 
installation and maintenance of electronic guarding equipment , if the combined 
entity  ceases to sub -contract these services from third party providers as a result of 
the Transaction in Sweden, Norway, Finland, Belgium and the Netherlands .  
(157) This is because, although both Parties are already, pre-Transaction, active in the 
market for the installation and maintenance of electronic guarding equipment, they 
also procure such services from third party providers when they do not have the internal capa bility to provide  the relevant services  themselves .  
                                                 
265  Responses to questions 23 -23.1 of questionnaire Q6 to competitors.  
266  Response of the Notifying Party to Request for Information I -8, Annex 3.1, Market Share Norway 
Sweden ; For m CO,  Tables 6.60, 6.63 and 6.66.  
267  The Commission, for the purposes of this decision, does not assess whether the Transaction would 
result in input foreclosure of the combined entity’s rivals in the upstream market for the installation and maintenance of electronic guarding equipment, by the combined entity refusing to sub -contract 
these services to its rival providers, for the following reasons. In the first place, the Parties are not significant players in the upstream market  for the installation and maintenance of electronic guarding 
equipment  to third party providers. In particular, in Sweden, only Stanley Security is active and the 
market share of the combined entity is estimated by the Notifying Party to be [0 -5]% in 2021. In 
Norway, Finland and Belgi um, where both Parties are active, the market share of the combined entity 
in 2021 would be [0 -5]%, [5 -10]% and [0- 5]% respectively, whilst none of the Parties are active in 
this market in the Netherlands.  
44 5.2.3.3.1. The Notifying Party’s view  
(158) Table 16 below provides an overview of the Parties’ purchasing  shares of 
installation and maintenance of electronic guarding equipment from third party 
providers  in Sweden  in 2021.  
Table 16: Purchasing Shares of Installation and maintenance of electronic guarding 
equipment from third party providers in Sweden in 2021  
Supplier  Purchasing shares (% per 
value )268  
Securitas  [5-10]%  
Stanley Security  [0-5]% 
Combined  [5-10]%  
Avarn  [5-10]%  
Others  [80-90]%  
Total  100%  
Source: Parties’ purchasing data269 
(159) Table 17 below provides an overview of the Parties’ purchasing  shares of 
installation and maintenance of electronic guarding equipment from third party providers  in Norway in 2021.  
Table 17: Purchasing Shares of Installation and maintenance of electronic guarding 
equipment from third party providers in Norway in 2021  
Supplier   Purchasing shares ( % per 
value)270  
Securitas  [0-5]% 
Stanley Security  [0-5]% 
Combined  [5-10]%  
LåssenteretAS  [0-5]% 
Certego  [0-5]% 
Verisure  [0-5]% 
Schneider  [20-30]%  
Others  [60-70]%  
Total  100%  
Source: Parties’ purchasing data271 
(160) Table 18 below provides an overview of the Parties’ purchasing  shares of 
installation and maintenance of electronic guarding equipment from third party 
providers  in Finland in 2021.  
                                                 
268  The Notifying Party does not provide informati on on the overall value of alarm response services 
purchased by security services providers in 2021 in Sweden.  
269  Response of the Notifying Party to Request for Information I -12, Table 1.6.  
270  The Notifying Party does not provide information on the overa ll value of alarm response services 
purchased by security services providers in 2021 in Norway.  
271  Response of the Notifying Party to Request for Information I -12, Table 1.7.  
45 Table 18: Purchasing Shares of Installation and maintenance of electronic guarding 
equipment from third party providers in Finland in 2021  
Supplier  Purchasing shares (% per 
value)272 
Securitas  [5-10]%  
Stanley Security  [0-5]% 
Combined  [5-10]%  
Others  [90-100]%  
Total  100%  
Source: Parties’ purchasing data273 
(161) Table 19 below provides an overview of the Parties’ purchasing  shares of 
installation and maintenance of electronic guarding equipment from third party 
providers  in Belgium in 2021.  
Table 19: Purchasing Shares of Installation and maintenance of electronic guarding 
equipment from third party providers in Belgium in 2021  
Supplier  Purchasing shares (% per 
value)274 
Securitas  [0-5]% 
Stanley Security  [20-30]%  
Combined  [20-30]%  
Others  [70-80]%  
Total  100%  
Source: Parties’ purchasing data275 
(162) Table 20 below provides an overview of the Parties’ purchasing  shares of 
installation and maintenance of electronic guarding equipment from third party 
providers  in the Netherlands in 2021.  
Table 20: Purchasing Shares of Installation and maintenance of electronic guarding 
equipment from third party providers in the Netherlands in 2021  
Supplier  Purchasing shares (% per value)276 
Securitas  [0-5]% 
Stanley Security  [0-5]% 
Combined  [5-10]%  
Others  [90-100]%  
Total  100%  
Source: Parties’ purchasing data277 
(163) The Notifying Party submits that in none of the geographically affected markets , 
the combined entity will have the ability or the incentive  to engage in foreclosure 
of the market for the installation and maintenance of electronic guarding 
equipment. This is primarily , because  the combined entity does not have sufficient 
                                                 
272  The Notifying Party does not provide information on the overall value of alarm response services 
purchased by security services providers in 2021 in Finland.  
273  Response of the Notifying Party to Request for Information I -12, Table 1.8.  
274  The Notifying Party does not provide information on the overall value of alarm response services purchased by security services providers in 2021 in Belgium.  
275  Response of the Notifying Party to Request for Information I -12, Table 1.9.  
276  The Notifying Party does not provide information on the overall value of alarm response services purcha sed by security services providers in 2021 in the Netherlands.  
277  Response of the Notifying Party to Request for Information I -12, Table 1.10.  
46 market power to do so and credible alternatives to the combined entity exist in each 
of the geographic markets .278 The Notifying Party also explains that, in the security 
services industry, competitors often  rely on one another to sub -contra ct a range of  
services , and therefore, it would be in the combined entity’s interest  to not 
jeopardise those  by enga ging into foreclosure strategies .279  
5.2.3.3.2. The Commission’s assessment  
5.2.3.3.2.1. Ability to foreclose Electronic Guarding equipment providers  
(164) As regards the combined entity’s ability to engage in customer foreclosure to the detriment of electronic guarding providers  in Swe den, Norway, Finland, Belgium 
and the Netherlands, the Commission notes the following.  
(165) First, the combined entity does not have  a significant  degree of market power in 
the installation a nd maintenance of electronic guarding equipment  to non-
residential cus tomers . More specifically, the Notifying Party submits that this 
product market is fragmented in all of the above -mentioned geographic markets, 
with numerous small competitors active therein. In particular, the Notifying Party 
indicates between 6 -9 competi tors active in this market in each of the above -
mentioned geographic markets , with similarly low market shares to those of the 
combined entity.
280  
(166) In addition, in the downstream market for the  installation and maintenance of 
electronic guarding equipment  to non-residential customers , according to the 
Notifying Party’s submission, the combined entity’s market share would amount to ~[0-5]%, ~ [5-10]%, ~ [5-10]%, ~ [10-20]% and ~ [10-20]% in the Netherlands, 
Norway, Belgium, Sweden and Finland in 2020 respective ly.
281 Therefore, their 
demand for sub-contracting these services from third party providers would be 
fundamentally low.  
(167) Second, the demand of the Parties  for installation and maintenance of electronic 
guarding equipment services from third party providers  is small, partly because of 
their low market share, but also because already pre -Transaction, the Parties 
provide these services to a large extent in -house.  
(168) In the first place,  as demonstrated in Table 16-Table 20 above, the combined 
entity’s purchasing share for the installation and maintenance of electronic 
guarding equipment services from third party providers in 2021 is low, amounting 
to […]% in all of the above mentioned countries, with the exception of Belgium , 
where the combined entity’s purchasing share is slig htly higher but still moderate , 
at [20-30]%.282  
(169) In the second place, according to the Notifying Party, Securitas did not purchase 
any installation and maintenance of electronic guarding equipment services from 
third party providers in Belgium, the Netherlands and Norway in 2020.283 
However, in the case of Finland and Sweden, Securitas  purchased installation and 
                                                 
278  Form CO, paragraph 58(a).  
279  Form CO, paragraph 156 and Table 6.2.  
280  Form CO, Annex 7.1, Parties’ market s hare.  
281  Form CO, Annex 8.1, Parties’ market share.  
282  Response of the Notifying Party to Request for Information I -12, Tables 1.6- 1.1-.  
283  Form CO, Table 6.1.  
47 maintenance of electronic guarding equipment services from third party 
competitors representing  [50-60]% and [90-100]% of its overall sales to end -
customers in this product market in 2020.284  
(170) In the third place, Stanley Security  focuses on the installation and maintenance of 
electronic guarding equipment and sources the vast majority of its needs in-house. 
In particular, Stanley Security purchased installation and maintenance of electronic 
guarding equipment services  from third-party providers represent ing only a small 
fragment of its overall sales to end-customers in this product market. More 
specifically, in 2020, Stanley purchased installation and maintenance of electronic guarding equipment services from third party competitors representing [5-10]%, [20-30]%, [5-10]%, [10-20]% and [10-20]% of its overall revenues from the 
installation and maintenance of electronic guardin g equipment in Belgium, the 
Netherlands, Finland, Sweden and Norway respectively.
285  
(171) Third , even in the cases where the Parties rely heavily on sub-contracting the 
installation and maintenance of electronic guarding equipment from third party providers (i.e . in the case of Securitas in Finland and Sweden), the volume of sub-
contracted services is very limited. For instance, Securitas’ sales in the market for 
installation and maintenance of electronic guarding equipment  in Sweden in 2020 
amounted to EUR […], representing only [0-5]% of the overall market for non-
residential customers. Likewise, in Finland, Securitas’ sales in the market for 
installation and maintenance of electronic guarding equipment  amounted to 
EUR  […], representing only [0-5]% of the overal l market for non-residential 
customers in 2020.
286  
(172) In the first  place, Securitas’ internal documents prepared in the ordinary course of 
business, suggest that, although it  subcontracts a number of regional and local 
players , it already pre -Transaction sub-c ontracts those services from Stanley 
Security and Securitas Direct (which was originally part of Securitas and although 
the brand is currently operated by Verisure, the two entities are still cooperating 
closely) .287 For instance, in Sweden in 2020, Securita s’ spending on sub-
subcontractors for the installation and maintenance of electronic guarding 
equipment services amounted to SEK […] (~EUR […]), of which ~ [40-50]%, 
amounting to SEK […] (~EUR […]), was purchased from Stanley Security and 
Securitas Direct .288 
(173) In the second place, the Parties submit that Stanley Security does not have internal 
spare capacity in any of the relevant markets where it is active  and that therefore 
would not be able to cover a substantial proportion of services currently outsourced 
by Securitas to third parties without hiring additional staff. This is because 
maintaining excess staff would represent a cost inefficiency for Stanley Security 
and, as such, it  attempts to cover its staffing needs in the ordinary course of 
business, hiring any additional staff as required and to balance any peaks in 
                                                 
284  ibid.  
285  Form CO, paragraph 6.2.  
286  Form CO, Annex 7.1, Parties’ market shares.  
287  Minutes of a conference call with a competitor, dated 30 May 2022, paragraph 14.  
288  Response of the Notifying Party to Request for Information I -8, Annex Securitas 16(vi)12, Securitas 
Sweden business plan 2021, slide 51.  
48 demand by relying on sub-contractors. Indeed, as indicated in Tabl e 16-Table 20 
above, in most of these markets, Stanley Security also relies on sub-contractors.289 
(174) Fourth, evidence in the Commission’s file highlights  that sub-contracting is an 
important element of Securitas’ business model  (see paragraph (172)  above), 
especially with regard to the installation and maintenance of electronic guarding 
equipment market  and there is no indication that the combined entity will, post -
Transaction, deviate from this business model . More specifically, an internal 
document prepa red by Securitas in the ordinary course of business indicates that 
the benefits of a business model that focuses on sub-contracting third party 
providers for the installation and maintenance of electronic guarding equipment, is 
that the sub-contractor face s the risk, whilst Securitas still makes a good profit 
margin from its sales.290 
(175) In any event, the Commission notes that  none of the respondents to the its  market 
investigation raised such foreclosure concerns , based on the Parties’ conduct pre -
Transaction, with the exception of one  competitor with respect to one of the 
relevant geographic markets .291 However, evidence in the Commission’s file 
suggest s that this competitor has not been one of the Parties’ largest sub -
contract ing partner in the installation and maintenance of electronic guarding 
equipment in the past,292 whilst no cooperation has taken place between Securitas 
and the competitors  recently.293 The competitor did not support its concern with 
sufficient evidence, whilst none of the remaining respondents to the Commission’s market investigation expressed similar concerns.  
5.2.3.3.3. Conclusion  
(176) In light of the above, the Commission concludes that the Transa ction does not give 
rise to serious doubts regarding its compatibility with the internal market as a result of foreclosure  in the market for the installation and maintenance of electronic 
guarding equipment , in particular due to the lack of ability of the combined entity 
to foreclose electronic guarding competitors  in Sweden, Finland, Norway, Belgium 
and the Netherlands. 
5.2.4. Conglomerate links  
(177) In this Section, the Commission assesses whether the Transaction would result in  
foreclosure of the Parties’ rivals by way of tying or bundling practices in any other 
markets where  the Transaction may have a significant impact .  
(178) In this respect, t he Commission considers the Parties’ activities in Sweden, 
Norway, Finland, the Netherlands and Belgium in i) manned guarding and  
installation and maintenance of  electronic guarding  equipment for non-residential 
customers ; ii) manned guarding and alarm monitoring and response for non-
                                                 
289  Form CO, paragraph 159 and ff.  
290  Response of the Notifying Party to Request for Information I -8, Annex Securitas 16(vi)12, Securitas 
Sweden business plan 2021, slide 50.  
291  Response to question 3.1 of Questionnaire Q6 to competitors; Minutes of a conference call with a 
competitor, da ted 2 February 2022, paragraph 19 and et seq.  
292  Response of the Notifying Party to Request for Information I -8, Annex Securitas 16(vi)12, Securitas 
Sweden business plan 2021, slide 51; and, Response of the Notifying Party to Request for Information I -12, Tables 2.1- 2.3.  
293  Response to question 3.1 of Questionnaire Q6 to competitors.  
49 residential customers  and iii) electronic guarding and alarm monitoring and 
response  for non-reside ntial customers .294 
5.2.4.1. Manned guarding and electronic guarding for non-residential customers   
5.2.4.1.1. The Notifying Party’s view  
(179) The Notifying Party submits that the Transaction would not give rise to 
competition concerns related to tying or bundling of manned guarding  with 
electronic guarding services. According to the Notifying Party, post-Transaction, 
Securitas would not have the ability to engage in any foreclosure strategies. T his is 
because (i) post -Transaction, the merged entity would not have market power in 
any electronic or manned guarding market and in addition, the Transaction would 
not affect the market position of the merged entity in  any manned guarding 
market;295 (ii) the merged entity would continue to face competition from several 
established competitors in all manned guarding markets post -Transaction;296 
(iii) the majority of customers purchasing electronic guarding services does not 
require manned guarding services;297 (iv) customers usually do not purchase 
electronic and manned guarding services simultaneously;298 (v) in particular 
significant customers will determine their security needs by themselves and source the security services needed  via tenders , leaving no space for bundling by service 
providers;
299 and (vi)  post-Transaction, Securit as will continue to face competition 
from fully- integrated suppliers, such as Avarn or G4S.300 
(180) In addition, the Notifying Party submits that post -Transaction, the merged entity 
would also not have the incentive to engage in any foreclosure strategies. This is because (i) manned guarding services are required only by a very small subset of 
customers purchasing electronic guarding services , which  would limit the 
profitability of any foreclosure s trategy;
301 (ii) Securitas’ rivals would also be able 
to offer bundled services;302 and (iii) Securitas is already active across these 
markets (either directly or through subcontracting) and has so far not attempted to 
leverage  its position from one market to another.303 
(181) Lastly, the Notifying Party submits that a hypothetical tying or bundling strategy would not have a significant adverse effect on competition in the markets for 
manned guarding and electronic guarding for non-residential customers , as rivals 
woul d not be  prevented from competing effectively. This is because (i) post -
Transaction, Securitas would continue to face strong competitors which could offer 
manned guarding with other security services, such as Avarn or G4S;
304 (ii) the 
effect of a leveraging strateg y based on Securitas’ position in the manned guarding 
                                                 
294  This decision assesses the conglomerate relationships resulting from the relationships between two of 
the aforementioned services. The considerations expressed in this Section however also apply, mutatis mutandis , to the relationship between all three of these services combined (as in: manned 
guarding, alarm monitoring and response, electronic guarding).  
295  Form CO, paragraphs 635- 645. 
296  Form CO, paragraph 655.  
297  Form CO, paragraph 656.  
298  Form CO, parag raph 657.  
299  Form CO, paragraph  658.  
300  Form CO, paragraph 659.  
301  Form CO, paragraph 680.  
302  Form CO, paragraph 681.  
303  Form CO, paragraph 682.  
304  Form CO, paragraph 694.  
50 market would be limited to a small set of customers, as the majority of non-
residential electronic guarding customers does not require manned guarding;305 and 
(iii) Securitas’ inability pre-Transaction to leverage its position in manned guarding 
markets to other security markets suggest that such a strategy would be 
ineffective.306  
5.2.4.1.2. The Commission’s assessment  
5.2.4.1.2.1. Ability to foreclose  
(182) As regards the combined entity’s ability to engage in forec losure via tying or 
bundling of electronic guarding services for non-residential customers with manned guarding services in Sweden, Finland, Norway, Belgium and the Netherlands, the 
Commission notes the following.  
(183) First, as a prerequisite to have the abili ty to engage in foreclosure through bundling 
or tying strategies, the combined entity must have a significant degree of market 
power in one of the closely related markets .
307  
(184) On the one hand, t he market shares of Securitas in the markets for manned 
guarding  in Sweden, Norway, Finland, the Netherlands and Belgium are high, 
suggesting a degree of market power in these markets. Specifically, as shown in Table 21-Table 25, Securitas is the largest player in Sweden (market s hare 
[40-50]% in 2020), Norway (market share  [40-50]% in 2020), Finland (market 
share [30-40]% in 2020) and Belgium (market share [30-40]% in 2020). In all  these 
countries, Securitas continues to face competition from one significant, though 
smaller competitor, namely either Avarn (Sweden, Norway, Finland) or G4S 
(Belgium). Furthermore, in the Netherlands, Securitas also has a significant market share (market share [30-40]% in 2020), however continues to face competition 
from two slightly larger competitors, namely Trigion (market share [30-40]% in 
2020) and G4S (market share [30-40]% in 2020).
308 The Transaction does not lead 
to any further increment in manned guarding services , as Stanley Security is not 
active in these services  the EEA.309 
(185) Tables 21-25 below provide an overview of the market shares of the Parties and 
their competitors in manned guardi ng services in Sweden, Norway, Finland, 
Belgium and the Netherlands between 2018-2020, as submitted by the Notifying 
Party.  
Table 21: Manned Guarding in Sweden  
 
Market Participant  2018  2019  2020  
Value 
(MEUR)  Sha re  ( %)  Value 
(MEUR)  Sha re  ( %)  Value 
(MEUR)  Sha re  ( %)  
Securitas  […] [40-50]%  […] [40-50]%  […] [40-50]%  
Stanley Security  […] [0-5]% […] [0-5]% […] [0-5]% 
Combined  […] [40-50]%  […] [40-50]%  […] [40-50]%  
Avarn  […] [20-30]%  […] [20-30]%  […] [20-30]%  
Addici  […] [0-5]% […] [0-5]% […] [0-5]% 
                                                 
305  Form CO, paragraph 695.  
306  Form CO, paragraph 696.  
307  Non-Horizontal Merger Guidelines, paragraph 99.  
308  Form CO, Annex 7.1.  
309  Form CO, paragraph 249.  
51  
Market Participant  2018  2019  2020  
Value 
(MEUR)  Sha re  ( %)  Value 
(MEUR)  Sha re  ( %)  Value 
(MEUR)  Sha re  ( %)  
Te mpest  […] [0-5]% […] [0-5]% […] [0-5]% 
Commuter  […] [0-5]% […] [0-5]% […] [0-5]% 
Rapid  […] [0-5]% […] [0-5]% […] [0-5]% 
Vesper  […] [0-5]% […] [0-5]% […] [0-5]% 
Cubsec  […] [0-5]% […] [0-5]% […] [0-5]% 
Estate  […] [0-5]% […] [0-5]% […] [0-5]% 
Bevakning  […] [0-5]% […] [0-5]% […] [0-5]% 
Others  […] [10-20]%  […] [10-20]%  […] [10-20]%  
Total  […] 100.0%  […] 100.0%  […] 100.0%  
Source: Parties’ sales data and Securitas’ market size estimates310. 
Table 22: Manned Guarding in Norway  
 
Market Participant  2018  2019  2020  
Value 
(MEUR)  Sha re  ( %)  Value 
(MEUR)  Sha re  ( %)  Value 
(MEUR)  Sha re  ( %)  
Securitas  […] [50-60]%  […] [50-60]%  […] [40-50]%  
Stanley Security  […] [0-5]% […] [0-5]% […] [0-5]% 
Combined  […] [50-60]%  […] [50-60]%  […] [40-50]%  
Avarn  […] [30-40]%  […] [30-40]%  […] [40-50]%  
CitySecurityAS  […] [0-5]% […] [0-5]% […] [0-5]% 
TomaSecurity  […] [0-5]% […] [0-5]% […] [0-5]% 
Tryggvakt  […] [0-5]% […] [0-5]% […] [0-5]% 
Hønefossvaktselskap  […] [0-5]% […] [0-5]% […] [0-5]% 
GSS […] - […] - […] [0-5]% 
SOSSecurity  […] [0-5]% […] [0-5]% […] [0-5]% 
Others  […] [10-20]%  […] [5-10]%  […] [5-10]%  
Total  […] 100.0%  […] 100.0%  […] 100.0%  
Source: Parties’ sales data and Securitas’ market size estimates311 
Table 23: Manned Guarding in Finland  
 
Market 
Participant  2018  2019  2020  
Value (MEUR)  Sha re  ( %)  Value (MEUR)  Sha re  ( %)  Value (MEUR)  Sha re  ( %)  
Securitas  […] [30-40]%  […] [30-40]%  […] [30-40]%  
Stanley Security  […] [0-5]% […] [0-5]% […] [0-5]% 
Combined  […] [30-40]%  […] [30-40]%  […] [30-40]%  
Avarn  […] [30-40]%  […] [30-40]%  […] [30-40]%  
Relia Palvelut 
Oy […] [0-5]% […] [5-10]%  […] [5-10]%  
Palmia  […] [0-5]% […] [0-5]% […] [0-5]% 
ISS Palvelut Oy  […] [0-5]% […] [0-5]% […] [0-5]% 
Sydbevakning 
Ab […] [0-5]% […] [0-5]% […] [0-5]% 
Others  […] [10-20]%  […] [10-20]%  […] [10-20]%  
Total  […] 100.0%  […] 100.0%  […] 100.0%  
Source: Parties’ sales data and Securitas’ market size estimates312 
                                                 
310  Form CO , Annex 7.1, Parties’ market share. 
311  Form CO , Annex 7.1, Parties’ market share. 
312  Form CO , Annex 7.1, Parties’ market share. 
52 Table 24: Manned Guarding in Belgium 
 
Market 
Participant  2018  2019  2020  
Value (MEUR)  Sha re  ( %)  Value (MEUR)  Sha re  ( %)  Value (MEUR)  Sha re  ( %)  
Securitas  […] [30-40]%  […] [20-30]%  […] [30-40]%  
Stanley Security  […] [0-5]% […] [0-5]% […] [0-5]% 
Combined  […] [30-40]%  […] [20-30]%  […] [30-40]%  
G4S […] [20-30]%  […] [20-30]%  […] [20-30]%  
Seris  […] [5-10]%  […] [5-10]%  […] [5-10]%  
Protection Unit  […] [0-5]% […] [0-5]% […] [5-10]%  
Trigion  […] [0-5]% […] [0-5]% […] [0-5]% 
Others  […] [30-40]%  […] [40-50]%  […] [10-20]%  
Total  […] 100.0%  […] 100.0%  […] 100.0%  
Source: Parties’ sales data and Securitas’ market size estimates313. 
Table 25: Manned Guarding in the Netherlands  
 
Market 
Participant  2018  2019  2020  
Value (MEUR)  Sha re  ( %)  Value (MEUR)  Sha re  ( %)  Value (MEUR)  Sha re  ( %)  
Securitas  […] [20-30]%  […] [20-30]%  […] [30-40]%  
Stanley Security  […] [0-5]% […] [0-5]% […] [0-5]% 
Combined  […] [20-30]%  […] [20-30]%  […] [30-40]%  
Trigion  […] [30-40]%  […] [20-30]%  […] [30-40]%  
G4S […] [30-40]%  […] [30-40]%  […] [30-40]%  
Profi -sec […] [0-5]% […] [0-5]% […] [0-5]% 
Maat  […] [0-5]% […] [0-5]% […] [0-5]% 
Seris  […] [0-5]% […] [0-5]% […] [0-5]% 
Others  […] [0-5]% […] [0-5]% […] [0-5]% 
Total  […] 100.0%  […] 100.0%  […] 100.0%  
Source: Parties’ sales data and Securitas’ market size estimates314 
(186) In addition, in the  course of the market investigation, competitors and customers 
identified Securitas as the most competitive player in the manned guarding market 
in all five geographical markets, with only Avarn (in Norway, Sweden and 
Finland) as well as G4S and Trigion ( in Belgium  and the Netherlands) identified as 
credible alternative s.315 However , according to a competitor, in some remote  
locations in Sweden and Norway, Securitas may in fact be the only provider for 
manned guarding servic es and may leverage this position to force customers to also 
purchase their electronic guardin g services.316 Furthermore, there has been little or 
no significant entry in manned guarding services in the abovementioned countries 
over the last five years . 
(187) On the other hand, the majority of competitors responding to the market 
investigation does not believe that barriers to entry in manned guarding markets are 
high.317 Furthermore, despite Securitas’ high market shares, most customers 
responding to the market investigation did not consider Securitas’ manned 
                                                 
313  Form CO, Annex 7.1, Parties’ market share. 
314  Form CO , Annex 7.1, Parties’ market share. 
315  Responses to question s 11 and 11.1 of Questionnaires Q1- Q5 to Customers; and Responses to 
question 15.1.1. of Questionnaire Q6 to Competitors.  
316  Response by a competit or to question 29 of Questionnaire Q6 to Competitors. 
317  Responses to questions 23, 23.1. and 18.1- 18.6 of Questionnaire Q6 to Competitors.  
53 guarding services to be a “must -have”, as there remain other provider(s) available 
in each country.318  
(188) On balance , the above indicates that the combined entity will likely have a certain 
degree of market power i n the manned guarding markets in Sweden, Norway, 
Finland and Belgium, and to a lesser degree, in the Netherlands.  
(189) Second, the market shares of Securitas and Stanley Security in the markets for 
electronic guarding for non-residential customers in the above -mentioned Member 
States  are relatively low  (namely, below [20-30]%), suggesting that the combined 
entity would not have a significant degree of market power in these markets.319 
However, the majority of competitors having responded to the market investigati on 
considered barriers to entry to the electronic guarding markets for non-residential 
customers to be  moderate .320  
(190) Third , the purchasing patterns of security customers in the manned guarding and 
electronic guarding markets in Sweden, Norway, Finland, Belgium, and the 
Netherlands  suggest that , despite the combined entity’s potential market power in 
manned guarding, it would be difficult for the combined entity to engage in any 
tying or bundling foreclosure strategies with regard to electronic guarding s ervices  
successfully . According to the Parties’ estimates , only a small share 
(between  […]%) of their non-residential electronic guarding customers actually 
requires manned guarding services ,321 with the percentage of those purchasing 
these together , being e ven lower.322 Competitors responding to the market 
investigation confirmed that the share of their electronic guarding customers , which 
require manned guarding services , is relatively low.323 Thus, i f the combined entity 
were to engage in foreclosure strategie s by which it would leverage its position in 
manned guarding in order to gain market shares in electronic guarding  for non-
residential customers , it would only reach a small share of all potential electronic 
guarding customers, as the rest of these does not purchase manned guarding 
services . As stated in paragraph 100 of the Non-Horizontal Merger Guidelines, “ for 
foreclosure to be a potential concern it must be the case that there is a large 
common pool of customers for the individual products concerned ”. However, there 
is such no large common pool of customers  for these two services. Therefore, if the 
combined entity were to engage in foreclosure of electronic guarding competitors, 
there would be a considerable majority of the market that would remain unaffected. 
Furthermore, while the share of manned guarding customers requiring electronic 
guarding services is quite high, depending on the country ([…]%),324 even amongst 
these customers, only […]% procure manned guarding and electronic guarding services togeth er, according to the Parties’ estimates.
325 
(191) Fourth, the most important parameters that customers take into account when 
choosing a security service provider according to the market investigation,  are 
quality and specific functionalities of services, followed by price. By comparison, 
the ability of a security service provider to offer integrated services for alarm 
                                                 
318  Responses to question s 17, 17.1 and 17.2. of Questionnaires Q1- Q5 to Customers.  
319  Form CO, Annex 7.1.  
320  Respons es to questions 25 and 25.1. of Questionnaire Q6 to Competitors and see paragraph (78). 
321  Form CO, table 6.78. 
322  Form CO, table 6.80. 
323  Responses to questions 41.1- 41.6. of Questionnaire Q6 to Competitors. 
324  Form C O, table 6.94. 
325  Form CO, t able 6.96. 
54 monitoring and response, manned guarding and electronic guarding was considered 
of comparatively lesser importance by most customers responding to the market 
investigation.326 This would suggest that  as long as customers have the choice, they 
will likely choose providers based on quality, rather than accepting bundled or tied services by the  combined entity which are of lower quality.  
(192) Fifth , while customers responding to the market investigation have suggested that 
overall, there are medium high or high barriers to switching for all security services, including administrative costs and the t ime required for a new tender,
327 
the majority of competitors responded that they believe that should Securitas 
increase prices or provide lower quality services or switch the conditions for 
manned guarding services as part of a bundling strategy post-Transa ction , 
customers could easily switch to alternative providers.328  
(193) Sixth , the combined entity will have the advantage of being able to offer their 
services in a comprehensive, integrated manner. While a  competitor claimed that , 
post-Transaction, the combined  entity  would be the only competitor that would be 
able to offer fully integrated services, which would put them at a significant 
advantage in all security -markets in Sweden,329 the market investigation indicated 
that the combined entity will continue to fac e fully integrated suppliers which can 
offer manned and electric guarding services , also in Sweden. In particular, in the 
countries with Securitas’ highest market shares in manned guarding (Sweden, 
Norway and Finland), the combined entity will continue to compete with Avarn, 
which would be able to match the combined entity’s bundled offers .  
(194) Seventh , several (large, n on-residential) customers responding to the market 
investigation indicated that they are not concerned about the possibility of tying or bundling strategies, as they will continue to have the ability to purchase only the 
services needed and also to refuse the combination of services by Securitas, if they 
would want to purchase these separately. One customer stated that “ the client 
generally decides what services it wants to purchase ”.
330 Another stated that 
“customers will always be able to purchase products separately, if they wanted”.331 
In addition, some respondents indicated that manned guarding and electronic 
guarding may not be particularly suitable to be combined from a technological 
point of view, as “ [s]ynergies are mostly with the alarm monitoring and other 
technology -related services”, as opposed to the traditional manned guarding 
services.332  
(195) Lastly , Securitas has already been offering both manned and electronic guarding 
services (to non-residential customers) before the Tr ansaction. Despite this, the 
market investigation did not indicate that Securitas has bundled services to leverage 
its strength in manned guarding services  and gain share  in electronic guarding  for 
non-residential customers . While post -Transaction, Securitas would have different 
incen tives regarding bundling strategies, its ability to foreclose rivals  should not 
change , as the market where Securitas has strength that could be leveraged  
(manned guarding), will remain unaffected by the Transaction.  
                                                 
326  Response  to question s 13 and 13.1- 13.3. of questionnaires Q1- 5 to Customers.  
327  Response  to question s 16 and 16.1- 16.2.1. of questionnaires Q1- 5 to Customers.  
328  Response to questions 44 and 44.1- 44.4. of questionnaire Q6 to Competitors.  
329  Minutes of a conference call with a competitor, dated 2 February 2022.  
330  Minutes of a conference call with a customer, dated 15 February 2022.  
331  Minutes of a conference call with a customer, dated 16 February 2022.  
332  Responses to questions 49 and 49.1 of questionn aire Q6 to Competitors.  
55 (196) On balance, the considerations above s uggest that the combined entity will not 
have the ability to engage in foreclosure via tying or bundling of electronic 
guarding services with manned guarding services for non-residential customers in 
Sweden, Finland, Norway, Belgium and the Netherlands. 
5.2.4.1.2.2. Incentive to foreclose  
(197) The incentive to foreclose rivals through bundling or tying depends on the degree 
to which this strategy is profitable. The merged entity faces a trade -off between the 
possible costs associated with bundling or tying its products and t he possible gains 
from expanding market shares in the market(s) concerned, or as the case may be, 
being able to raise price in those market(s) due to its market power.333  
(198) First, the Commission considers the relative value of different product s. According 
to the Non-Horizontal Merger Guidelines, “ it is unlikely that the merged entity 
would be willing to forego sales on one highly profitable market in order to gain 
shares on another market where turnover is relatively small and profits are 
modest ”.334 Competitors responding to the market investigation suggested that 
electronic guarding is more profitable than manned guarding in terms of margin.335 
In addition, the national markets for electronic guarding for non-residential customers in the five relevant countries are also each larger in terms of overall 
turnover, than the respective manned guarding markets.
336 This would suggest that 
the combined entity would have an incentive to engage in conglomerate foreclosure 
strategies.  
(199) However, the combined overall turnover g enerated by Securitas pre -Transaction in 
the manned guarding markets is considerably higher in each Member State  than 
that generated by both Parties combined in the respective markets for electronic guarding  to non-residential customers.
337 More importantly, as stated in 
paragraph (190), relatively few non-residential electronic guarding customers even 
require manned guarding. It would thus likely not be profitable to risk foregoing 
sales in the combined entity’s highest grossing markets (manned guarding) to be 
able to increase their turnover in just a small share of another market (electronic 
guarding to non-residential customers).  
(200) Second, while Securitas is already offering both services, the Notifying Party 
claims that in “ instances where Securitas provides a combination of more than one 
security service to a customer in accordance with that customer ’s specific needs, 
Securitas does not engage in mixed bundling prac tices”, i.e., it does not offer a 
discount for the  combination of services as compared to the situation where those 
services are provided individually . Instead, when a combination (i.e., more than 
one) of security services is  supplied by Securitas , they are “ priced on a standalone 
basis, based on a monthly subscription-type fee ”.338 Similarly, in the cases where 
Stanley Security  offers bundled packages of different security services involving 
                                                 
333  Non-Horizontal Merger Guidelines, paragraph 105.  
334  Non-Horizontal Merger Guidelines, paragraph 107.  
335  Responses to questions 37 and 37.1 of questionnaire Q6 to Competitors.  
336  Form CO, Annex 7.1, Parties’ Market Share.  
337  Ibid.  
338  Form CO, paragraph 702.  
56 manned guarding (via -subcontracting), it does not offer preferent ial prices or 
discounts.339 
(201) The market investigation yielded mixed results as to whether the combined entity 
would have the incentive to change this approach and offer its services tied 
together or in bundles. Some competitors pointed towards the danger of S ecuritas 
combining their strong manned guarding offering with the high quality electronic 
guarding offering of Stanley Security  and that Securitas did offer multi -year 
bundled service -offers in the past.340 However, other competitors responded that 
such a st rategy would likely not be in the combined entity’s interest, as customers 
may not want to purchase these together and would continue to have the ability to 
switch to other suppliers.341 In th is regard, as shown in paragraph (194), the market 
investigation suggested that customers may have a significant amount of countervailing buyer power with regard to these markets.  
(202) On balance, the considerations above suggest that the combined will not have the incentive to engage in foreclosure via tying or bundling of electronic guarding 
services for non-residential customers with manned guarding services in Sweden, 
Finland, Norway, Belgium and the Netherlands , mainly due to the relatively 
limited profitability of a potential foreclosure strategy in the electronic guarding markets and the high likelihood that customers will continue to be able to choose to 
purchase these services  separately, should they prefer.  
(203) Given the conclusion that the combined entity will not have the ability and 
incentive to engage in the above -mentioned foreclosure strategies, the Commission 
will not analyse the potential effects of such foreclosure.  
5.2.4.1.3. Conclusion  
(204) In light of the above, the Commission conclude s that the Transaction does not give 
rise to serious doubts regarding its compatibility with the internal market because 
of conglomerate  foreclosure, in particular due to the lack of ability and incentive  of 
the combined entity to engage in tying or bundli ng foreclosure strategies with 
regard to manned guarding and electronic guarding for non-residential customers  in 
Sweden, Finland, Norway, Belgium and the Netherlands . 
5.2.4.2. Manned guarding and alarm monitoring and response  for non-residential customers  
5.2.4.2.1. The Notifying Party’s view  
(205) The Notifying Party submits that the Transaction would not give rise to competition concerns related to tying or bundling of manned guarding with alarm 
monitoring and response services in any of the markets. According to the Notifying 
Party, post -Transaction, Securitas would not have the ability to engage in any 
foreclosure strategies. This is because (i) post -Transaction, the merged entity 
would not have market power in any manned guarding or alarm monitoring and 
response market and in addition, the Transaction would not affect the market 
position of the merged entity on any manned guarding market;
342 (ii) the merged 
entity would continue to face competition from several established competitors in 
                                                 
339  Form CO, paragraph 703.  
340  Responses to questions 49 and 49.1 of questionnaire Q6 to Competitors.  
341  Responses to questions 49 and 49.1 of questionnaire Q6 to Competitors.  
342  Form CO, paragraphs 653- 645. 
57 all manned guarding markets pos t-Transaction;343 (iii) the majority of customers 
purchasing alarm monitoring and response  services does not require manned 
guarding services;344 (iv) in particular significant customers will determine their 
security needs by themselves and often launch tender processes, leaving no space 
for bundling by security service providers;345 and (v) post -Transaction, security 
will continue to face competition from fully-integra ted suppliers, such as Avarn 
or G4S.346 
(206) In addition, the Notifying Party submits that post -Transa ction, the merged entity 
would also not have the incentive to engage in any foreclosure strategies. This is 
because (i) manned guarding services are required only by a very small subset of 
customers purchasing alarm monitoring services , which would limit t he 
profitability of any foreclosure strategy;347 (ii) Securitas’ rivals would also be able 
to offer bundled services;348 (iii) Securitas is already active across these markets 
(either directly or through subcontracting) and has so far not attempted and was not  
able to leverage its position from one market to another.349 
(207) Lastly, the Notifying Party submits that a hypothetical tying or bundling strategy 
would not have a significant adverse effect on competition, as competitors would 
not be prevented from competing effectively. This is because (i) post -Transaction, 
Securitas would continue to face strong competitors which could offer manned 
guarding with other security services, such as Avarn or G4S;350 (ii) the effect of a 
leveraging strateg y based on Securitas’ posit ion in the manned guarding market 
would be limited to a small set of customers, as the majority of non-residential 
alarm monitoring and response customers does not require manned guarding;351 
and (iii) Securitas’ inability to leverage its position in manned guarding markets to 
other security markets suggest that such a strategy would be ineffective.352  
5.2.4.2.2. The Commission’s assessment  
5.2.4.2.2.1. Ability to foreclose  
(208) As regards the combined entity’s ability to engage in foreclosure via tying or 
bundling of alarm monitoring and response services for non-residential customers 
with manned guarding services in Sweden, Finland, Norway, Belgium and the 
Netherlands, the Commission notes the following.  
(209) First, a s determined in paragraphs (183) and (186), the combined entity will likely 
have a certain degree of market power in the manned guarding markets in Sweden, 
Norway, Finland and Belgium, and to a lesser degree, in the Netherlands.  
(210) Seco nd, as stated in Section  5.2.2.1, the Commission’s market investigation 
indicates that  the combined entity will likely not obtain a significant degree of 
market pow er in the markets  for alarm monitoring and response services for non-
                                                 
343  Form CO, paragraph 655.  
344  Form CO, paragraph 656.  
345  Form CO, paragraph 658.  
346  Form CO, paragraph 659.  
347  Form CO, paragraph 680.  
348  Form CO, paragraph 681.  
349  Form CO, paragraph 682.  
350  Form CO, paragraph 694.  
351  Form CO, paragraph 695.  
352  Form CO, paragraph 696.  
58 residential customers in Sweden and Norway, due to countervailing buyer power.  
In particular, any bundling strategy would be faced with a significant degree of 
countervailing buyer power by non-residential alarm monitoring and response 
customers, in particular those that require specialized or nationwide services.353 
Furthermore, as stated in Section s 5.2.2.2 and 5.2.2.3  , the Commission concluded 
that the combined entity will likely not have market power in the markets for alarm 
monitoring and response services  for non-residential customers in Finland, 
Belgium and the Netherlands .  
(211) Third , the purchasing patterns of security customers in the manned guarding and 
alarm monitoring and response markets in Sweden, Norway, Finland, Belgium, and 
the Netherlands suggest that, despite the combined entity’s potential market power 
in manned guarding, it would be difficult for the combined entity to engage in any 
tying or bundling foreclosure strategies with regard to alarm monitoring and 
response services successfully. According to the Parties’ estimates, only a small 
share (between […]%) of their non-residential alarm monitoring and response  
customers actually requires manned guarding services.354 Competitors responding 
to the market investigation confirmed that the share of t heir alarm monitoring and 
response customers which require manned guarding services is relatively low.355 
While the share of manned guarding customers requiring alarm monitoring and 
response  services is quite high depending on the country ([…]%),356 even among st 
these, only […]% procure manned guarding and alarm monitoring and response  
services together, according to the Parties’ estimates.357 Thus, if the combined 
entity were to engage in foreclosure strategies by which it would leverage its 
position in manned g uarding in order to gain market shares in alarm monitoring 
and response for non-residential customers, it would only reach a small share of all 
potential customers, as the rest of these does not purchase manned guarding 
services . Thus, there is no large common pool of customers  for these two services.  
(212) Fourth, the most important parameters that customers take into account when 
choosing a security service provider according to the market investigation,  are 
quality and specific functionalities of services, fo llowed by price. By comparison, 
the ability of a of security service provider to offer integrated services for alarm monitoring and response, manned guarding and electronic guarding was considered 
of comparatively lesser importance by most customers responding to the market 
investigation.
358 This would suggest that , as long as customers have the choice, 
they will likely choose providers based on quality, rather than accepting bundled or 
tied services by the combined entity which are of lower quality.  
(213) Fifth , while customers responding to the market investigation have suggested that 
overall, there are medium high or high barriers to switching for all security 
services, including administrative costs and the time required for a new tender,359 
competitors indicated that it is considerably more common to switch manned 
guarding providers at the end of a contract  than to switc h alarm monitoring and 
                                                 
353  See Section 5.2.2.1.2.  
354  Form CO, table 6.79. 
355  Responses to questions 40.1- 40.5. of Questionnaire Q6 to Competitors. 
356  Form C O, table 6.93.; See also Responses to questions 40.1- 40.5. of Questionnaire Q6 to 
Competitors.  
357  Form CO, table 6.95. 
358  Responses to question s 13 and 13.1- 13.3. of Questionnaires Q1- Q5 to Customers.  
359  Responses to question s 16 and 16.1- 16.2.1. of Questionnaires Q1- Q5 to Customers.  
59 response providers  at the end of a contract .360 This indicates that, should Securitas 
attempt to increase prices or provide lower quality services or switch the conditions 
for manned guarding services as part of a bundling strategy for alarm monitoring 
and response services  post -Transaction, customers may be more able and willing to 
switch their manned guarding provider, rather than their alarm monitoring and 
response provider.  
(214) Sixth , the combined entity will have the advantage of being able to offer their 
services in a comprehensive, integrated manner. While  a third party competitor  
claimed that , post-Transaction, the combined entity would be the only competitor 
that would be able to offer fully integrated services, which would put them at a significant advantage in all security -markets in Sweden,
361 the market investigation 
indicated that the combined entity will continue to face fully integrated suppliers 
which can offer manned guarding and alarm monitoring and response  services  to 
non-residential customers , also in Sweden. In particular in the countrie s with 
Securitas’ highest market shares in manned guarding (Sweden, Norway and 
Finland), the combined entity will continue to compete with Avarn, which would 
be able to match the combined entity’s offer.  
(215) Seventh , several (large, non-residential) customers  responding to the market 
investigation indicated that they are not concerned about the possibility of tying or bundling strategies, as they will continue to purchase only the services needed and 
also be able  to refuse the combination of services by Securi tas, if they would want 
to purchase these separately . One customer stated that “ the client generally decides 
what services it wants to purchase ”.
362 Another stated that “ customers will always 
be able to purchase products separately, if they wanted”.363  
(216) Lastly , Securitas has already been offering both manned guarding and alarm 
monitoring and response  services (to non-residential customers) before the 
Transaction. Despite this, the market investigation did not indicate that Securitas 
has bundled services to leverage its strength in manned guarding  services  and gain 
share in electronic guarding  for non-residential customers . While post -Transaction, 
Securitas would have different incentives regarding bundling strategies, its ability to foreclose rivals should not c hange, as the market where Securitas has strength 
that could be leveraged (manned guarding), will remain unaffected by the Transaction. On balance, the Commission considers, on the basis of the 
considerations above, that the combined will not have the abil ity to engage in 
foreclosure via tying or bundling of alarm monitoring and response  services for 
non-residential customers with manned guarding services in Sweden, Finland, Norway, Belgium and the Netherlands. 
5.2.4.2.2.2. Incentive to foreclose  
(217) First, competitors responding to the market investigation indicated that alarm 
monitoring and response services are more profitable than manned guarding in 
terms of margin.
364 However, national markets for alarm monitoring and response 
services for non-residential customers in the  five relevant countries are each 
considerably smaller in terms of overall turnover, than the respective manned 
                                                 
360  Responses to question 28 of Questionnaire Q6 to Competitors.  
361  Minutes of a conference call with a competitor, dated 2 February 2022.  
362  Minutes of a conference call with a customer, dated 15 February 2022.  
363  Minutes of a conference call with a customer, dated 16 February 2022.  
364  Responses to questions 37 and 37.1. of  Questionnaire Q6 to Competitors. 
60 guarding markets.365 Furthermore, the combined overall turnover generated by 
Securitas pre -Transaction in the manned guarding markets is considera bly higher 
than that generated by both Parties combined in the respective markets for alarm 
monitoring to non-residential customers. To illustrate, the turnover generated by 
Securitas in manned guarding in Sweden in 2020 (EUR […]) is even significantly 
larger than the overall size of the non-residential alarm monitoring and response 
market in Sweden over the same year (EUR […]).366 Furthermore, as stated in 
paragraph (211), relatively few alarm monitoring and response customers even 
require manned guarding. It would thus likely not be profitable to risk foregoing 
sales in the combined entity’s highest grossing markets (manned guarding) to be 
able to increase their turnover in just a small share of another market (alarm 
monitoring and response to non-residential customers).  
(218) Second, while Securitas is already offering both services, the Notifying Party 
claims that in “ instances where Securitas provides a combination of mor e than one 
security service to a customer in accordance with that customer ’s specific needs, 
Securitas does not engage in mixed bundling practices ”, i.e., it does not offer a 
discount for the  combination of services as compared to the situation where those  
services are provided individually . Instead, when a combination (i.e., more than 
one) of security services is  supplied by Securitas , they are “ priced on a standalone 
basis, based on a monthly subscription-type fee ”.367 Similarly, in the cases where 
Stanley Security offers bundled packages of different security services involving 
manned guarding (via -subcontracting), it does not offer preferential prices or 
discounts.368 In addition and as stated above, the market investigation did not 
indicate that Securitas h as bundled services to leverage its strength in manned 
guarding services and gain share s in electronic guarding for non-residential 
customers. 
(219) The majority of c ompetitors and customers responding to the market investigation  
confirmed that they did not expe ct it to be likely that the combined entity would tie 
(as in not sell separately anymore) its manned guarding and alarm monitoring and 
response products for non-residential customers together post -Transaction.369 One 
customer responded that “ [c]ompanies do not always demand a complete solution 
from the market. If this is only offered by suppliers as a total solution, you make the purchase market smaller for yourself and thus the competition stronger ”.
370 
Another customer stated that “ Manned guarding is a very i mportant part of 
Securitas activities, I doubt they would be willing to jeopardize their competitiveness by imposing customer other services .”
371 
(220) To the contrary, the majority of customers and competitors responding to the market investigation indicated that  it might  be in the combined entity’s interest to 
offer commercial bundles including manned guarding and alarm monitoring and response services to non-residential customers. Customers seemed to however 
suggest , that this might be a positive aspect, with one customer stating “ [t]his is 
                                                 
365  Form CO, Annex 7.1.  
366  Ibid.  
367  Form CO, paragraph 702.  
368  Form CO, paragraph 703.  
369  Responses to question s 21 and 21.1. of Questionnaires Q1- Q5 to Customers. Responses to 
questions  45 and 45.1- 45.4 of Questionnaire Q6 to Competitors.  
370  Response by a customer to question s 21 and 21.1. of Questionnaires Q4 to Customers. 
371  Response by a customer to question s 21 and 21.1. of Questionnaires Q5 to Customers. 
61 probably one of the main benefits of the merger for commercial clients ”.372 In this 
regard and as indicated in the Non-Horizontal Merger Guidelines, commercial 
bundling practices do not have to be inherently anticompetitive, as customers may 
in fact have a strong incentive to buy a range of products from a single source373 
and such practices may also lead to cost -savings and other benefits to customers.374 
(221) On balance, the Commission considers, on the basis of the considerations above , 
that the combined entity will have the incentive to engage in foreclosure via tying 
or bundling alarm monitoring and response services for non-residential customers with manned guarding services in Sweden, Finland, Norway, Belgium and the 
Netherlands , ma inly due to the relatively limited profitability of a potential 
foreclosure strategy in the alarm monitoring and response markets . 
(222) Given the conclusion that the combined entity will not have the ability and incentive to engage in the above -mentioned forecl osure strategies, the Commission 
will not analyse the potential effects of such foreclosure.  
5.2.4.2.3. Conclusion  
(223) In light of the above, the Commission concludes that the Transaction does not give 
rise to serious doubts regarding its compatibility with the internal market because 
of conglomerate  foreclosure, in particular due to the lack of ability and incentive  of 
the combined entity to engage in tying or bundling foreclosure strategies with 
regard to manned guarding and alarm monitoring and response services for non-
residential customers  in Sweden, Finland, Norway, Belgium and the Netherlands. 
5.2.4.3. Electronic guarding and alarm monitoring and response  
5.2.4.3.1. The Notifying Party’s view  
(224) The Notifying Party submits that the Transaction would not give rise to 
competition concerns related to tying or bundling of electronic guarding services 
with alarm monitoring and response services for non-residential customers  in any 
of the markets. According to the Notifying Party, post -Transaction, Securitas 
would not have the ability to engage in any tying or bundling foreclosure strategies. 
This is because (i) post -Transaction, the merged entity would not have a substantial 
degree of market power in any alarm monitoring and response or electronic 
guarding market;
375 (ii) the merged entity would continue to face competition from 
several established competitors in all alarm monitoring and response as  well as 
electronic guarding markets post -Transaction;376 and (iii) a significant proportion 
of customers does not purchase electronic guarding and alarm monitoring and 
response services simultaneously or purchases only one of the two services 
altogether .377  
(225) In addition, the Notifying Party submits that post -Transaction, the merged entity 
would also not have the incentive to engage in any foreclosure strategies, as it 
would not be able to convince its customers to switch away from the electronic 
                                                 
372  Response by a customer to question s 22 and 22.1. of Questionnaires Q1 to Customers.  
373  Non-Horizontal Merger Guidelines, paragraph 104.  
374  Non-Horizontal Merger Guidelines, paragraph s 116- 118. 
375  Form CO, paragraphs 620- 621. 
376  Form CO, paragraph 622 ff.  
377  Form CO, paragraph 625 ff.  
62 guarding or al arm monitoring and response services that they may currently 
procure from a competitor.378 This is because (i) customers which already have 
alarm systems installed would likely not require electronic guarding services, 
which would exclude Securitas from competing in a significant market -segment;379 
(ii) a significant segment of customers have the preference to procure electronic 
guarding and alarm monitoring and response services separately;380 (iii) Securitas’ 
competitors would also be able to offer bundles to t hose customers, that would 
prefer purchasing the services in a bundle;381 (iv) Securitas would not have the 
incentive to jeopardize the relationships to competitors which may act as potential 
sub-contractors or customers of Securitas;382 and (v) Securitas is already active 
across these markets and has so far not attempted and was not able to leverage its position from one market to another.
383  
(226) Lastly, the Notifying Party submits that a hypothetical tying or bundling strategy 
would not have  a significant adverse effect on competition, as competitors would 
not be prevented from competing effectively. This is because (i) post -Transaction, 
a significant number of competitors would remain which could discipline any 
attempted foreclosure strategy; (ii) the presence of strong countervailing buyer 
power;384 (iii) the ability of competitors to react to bundling strategies by offering 
bundles of their own;385 and (iv) low barriers to entry to both alarm monitoring and 
response as well as electronic guardi ng markets.386  
5.2.4.3.2. The Commission’s assessment  
5.2.4.3.2.1. Ability to foreclose  
(227) As regards the combined entity’s ability to engage in foreclosure via tying or 
bundling of electronic guarding services for non-residential customers with alarm 
monitoring and response service s for non-residential customers in Sweden, 
Finland, Norway, Belgium and the Netherlands, the Commission notes the 
following.  
(228) On the one hand, the purchasing patterns of non-residential security customers in 
the electronic guarding and alarm monitoring and response markets in these five 
Member States  suggest that the combined entity may in fact have the ability to tie 
or bundle these products, as they have a large common pool of customers. The majority of competitors responding to the market investigation indicated that the 
share of customers requiring electronic guarding services that also source  alarm 
monitoring and response services is high and vice-versa.
387 The majority of 
competitors responding to the market investigation also indicated that of those customers who purchase both services, the majority purchases them together.
388  
                                                 
378  Form CO, paragraph 635.  
379  Form CO, paragraph 636.  
380  Form CO, paragraph 637.  
381  Form CO, paragraph 638.  
382  Form CO, paragraph 639.  
383  Form CO, paragraph 640.  
384  Form CO, paragraph 644.  
385  Form CO, paragraph 645.  
386  Form CO, paragraph 647.  
387  Responses to questions 42 and 42.1- 42.6. of Questionnaire Q6 to Competitors.  
388  Responses  to question 42 .3 of Questionnaire Q6 to Competitors.  
63 (229) On the other hand, first, as stated in Section  5.2.2, the Commission’s market 
investigation indicates that the combined entity will likely not  obtain a significant 
degree of market power in the markets for alarm monitoring and response services 
for non-residential customers in Sweden and Norway due to signi ficant 
countervailing buyer power. In particular, any bundling strategy would be faced 
with a significant degree of countervailing purchaser power by non-residential alarm monitoring and response customers, in particular those that require 
specialized or nationwide services.
389 Furthermore, the Commission concluded that 
the combined entity will likely not have market power in the market for alarm monitoring and response services for non-residential customers in Finland, Belgium and the Netherlands.
  
(230) Second, t he market shares of Securitas and Stanley Security in the markets for 
electronic guarding for non-residential customers in the above -mentioned Member 
States  are relatively low  (namely, below 20%), suggesting that the combined entity 
would not have a signif icant degree of market power in these markets.390 The 
majority of competitors having responded to the market investigation considered 
barriers to entry to the electronic guarding markets for non-residential customers to 
be moderate .391  
(231) Third , the most importa nt parameters that customers take into account when 
choosing a security service provider according to the market investigation,  are 
quality and specific functionalities of services, followed by price. By comparison, 
the ability of a security service provider to offer integrated services for alarm 
monitoring and response, manned guarding and electronic guarding was considered 
of comparatively lesser importance by most customers responding to the market 
investigation.392 This would suggest that  as long as custo mers have the choice, they 
will likely choose providers based on quality, rather than accepting bundled or tied 
services by the combined entity which are of lower quality.  
(232) Fourth, while customers responding to the market investigation have suggested that 
overall, there are medium high or high barriers to switching for all security 
services, including administrative costs and the time required for a new tender,393 
the majority of competitors responding to the market investigation stated that 
should Securitas or Stanley Security increase prices or provide lower quality 
services for alarm monitoring and/or response services, customers could easily switch to alternative providers post -Transaction.
394 One competitor elaborated that 
“the common practice is that the c ustomer does not pay to change service 
provider ”.395 Another competitor stated that should the combined entity attempt to 
tie or bundle electronic guarding and alarm -monitoring and response services 
together, non-residential “ [c]ustomers have good opportunit y to switch suppliers 
and based on their procurement strategy either go with one or multiple 
suppliers .”396 
                                                 
389  See Section 5.2.2.1.2.  
390  See Form CO, Annex 7.1.  
391  Responses to questions 25 and 25.1. of Questionnaire Q6 to Competitors and see paragraph (78). 
392  Responses to question s 13 and 13.1- 13.3. of Questionnaires Q1- Q5 to Customers.  
393  Responses to question s 16 and 16.1- 16.2.1. of Questionnaires Q1- Q5 to Customers.  
394  Responses  to question 30 of Questionnaire Q6 to Competitors.  
395  Responses  by a competi tor to question 30 of Questionnaire Q6 to Competitors. 
396  Responses  by a competitor to question 47.2. of Questionnaire Q6 to Competitors. 
64 (233) Fifth , the combined entity will have the advantage of being able to offer their 
services in a comprehensive, integrated manner. While  a competitor claimed that , 
post-Transaction, the combined entity would be the only competitor that would be 
able to offer fully integrated services, which would put them at a significant 
advantage in all security -markets in Sweden,397 the market investigation indicated 
that the combined entity will continue to face fully integrated suppliers which can 
offer electronic  guarding and alarm monitoring and response  services  to non-
residential customers , also in Sweden. In particular in the countries with Securitas’ 
highest ma rket shares in manned guarding (Sweden, Norway and Finland), the 
combined entity will continue to compete with Avarn, which would be able to 
match the combined entity’s offer. A Norwegian customer concluded that “ Avarn 
considered a main competitor would pr event the described combination of services 
for fear of losing market share .”398 
(234) Sixth , several (large, non-residential) customers responding to the market 
investigation indicated that they are not concerned about the possibility of tying or bundling strategies, as they will continue to have the ability to request which 
services they want to purchase and also refuse the combination of services by 
Securitas, if they would wand to purchase these separately. One customer stated 
that “the client generally decides  what services it wants to purchase ”.
399 Another 
stated that “ customers will always be able to purchase products separately, if they 
wanted”.400  
(235) Lastly , both Stanley Security and to a lesser degree Securitas have been offering 
alarm monitoring and response as  well as electronic guarding services to non-
residential customers before the Transaction. Despite this, the market investigation 
did not indicate that either Parties have bundled their services in either of these 
markets to gain market shares  in the respe ctive other market. While  post-
Transaction, the combined entity would have different incentives regarding 
bundling strategies as it would gain market shares in both markets , in particular in 
alarm monitoring and response for non-residential customers, a cu stomer 
maintained that “ Securitas have had this combination of products before and back 
then products could be provided separately. That is same with their main competitors, as a customer you can buy the products separately .”
401  
(236) On balance, the  Commission considers, on the basis of the  considerations above , 
that the combined will not have the ability to engage in foreclosure via tying or bundling of electronic guarding services with alarm monitoring and response services for non-residential cust omers services in Sweden, Finland, Norway, 
Belgium and the Netherlands , mainly due to the lack of market power in both 
markets, the purchasing patterns in both markets and the continued ability of 
customers to switch providers and determine which services they would like to 
purchase . 
5.2.4.3.2.2. Incentive  to foreclose  
(237) On the one hand, while Securitas is already offering both services, the Notifying 
Party claims that in “ instances where Securitas provides a combination of more 
                                                 
397  Minutes of a conference call with a competitor dated 2 February 2022.  
398  Response by a customer to question 19.1. o f Questionnaire Q2 to Customers.  
399  Minutes of a conference call with a customer, dated 15 February 2022.  
400  Minutes of a conference call with a customer, dated 16 February 2022.  
401  Response by a customer to question 19.1. of Questionnaire Q1 to Customers.  
65 than one security service to a customer in accordance with that customer ’s specific 
needs, Securitas does not engage in mixed bundling practices ”, i.e., it does not 
offer a discount for the  combination of services as compared to the situation where 
those services are provided individually . Instead,  when a combination (i.e., more 
than one) of security services is  supplied by Securitas , they are “ priced on a 
standalone basis, based on a monthly subscription-type fee ”.402 Similarly, in the 
cases where Stanley offers bundled packages of different security services 
involving manned guarding (via -subcontracting), it does not offer preferential 
prices or discounts.403 In addition and as stated above, the market investigation did 
not indicate that Securitas has bundled services to leverage its strength in manned 
guarding services and gain share in electronic guarding for non-residential 
customers . 
(238) On the other hand,  competitors responding to the market investigation indicated 
that alarm monitoring and response services are slightly more profitable than electronic  guarding in terms of margin.
404 At the same time, the electronic guarding 
market for non-residential customers is considerably larger than the alarm 
monitoring and response market for these customers.405 The overall turnover that 
could be generated by increas ing market shares in the electronic guarding markets 
for non-residential customers is considerably higher than for alarm monitoring and 
response services to non-residential customers. In addition, as shown in 
paragraph (230), the share of customers purchasing both services (together) is high. 
This would indicate that the combined entity may have the incentive to leverage 
their position in alarm monitoring and res ponse markets for non-residential 
customers, to gain further market shares in the electronic guarding markets for non-
residential customers.  
(239) The market investigation provided mixed results as to whether the combined entity 
would have the incentive to tie electronic guarding and alarm monitoring and response products together for non-residential customers , post-Transaction. One 
competitor responded that “ [p]ost Transaction, Sec uritas will be the dominant 
supplier of alarm monitoring services to non-residential customers. It is likely it 
will try to leverage this position by tying the sale of these services to customers 
also purchasing its electronic guarding services (purchased from Stanley Security, 
the leading provider of such services).” To the contrary, another competitor stated 
that such practice “ would not be wise of them, that will only exclude them from 
parts of the market ”. A further competitor offered a more nuanced vie w, stating 
that “[i]n certain cases when the main product is the electronic guarding, this is operationally sensible but we do not see this transaction as changing the market; 
this has been and is the practice for certain cases. As a general rule, we belie ve 
they are selling the services separately .”
406 By comparison, customers responding 
to the market investigation were more sceptic with regard to the combined entity’s incentive to tie these services together. According to one customer, “ [t]he suppliers 
woul d lose contracts if they “forced” commercial clients into a single solution ”.
407  
(240) However , both customers and competitors deemed it likely that post -Transaction, 
the combined entity will offer its electronic guarding and alarm monitoring and 
                                                 
402  Form CO, paragraph 702.  
403  Form CO, paragraph 703.  
404  Responses to questions 37 and 37.1. of Questionnaire Q6 to Competitors. 
405  Form CO, Annex 7.1.  
406  Responses  to question 47 of Questionnaire Q6 to Competitors.  
407  Response by a customer to question 19.1. of Questionnaire Q1 to Customers.  
66 response service s in commercial bundles to non-residential customers.408 Several 
customers in fact perceived this as an advantage to customers, leading to  synergies 
as well as to a more comprehensive and/or cheaper offer.409 To the contrary, one 
competitor responding to the m arket investigation expects such bundling practices 
would have a negative effect on price, stating that “[ i]t is more likely that the 
Parties will keep a high price level and tie the products since there is a lack of 
competition and the Parties are dominant in several markets .”410 However, this 
concern was not further substantiated.  
(241) On balance , the Commission considers, on the basis of the considerations above , 
that the combined entity may have the incentive to engage in foreclosure via 
bundling of alarm monitoring and response services for non-residential customers 
with manned guarding services in Sweden, Finland, Norway, Belgium and the 
Netherlands , mainly due to the likely profitability of such practice .  
(242) Given the conclusion that the combined entity wi ll not have the ability to engage in 
the above -mentioned foreclosure strategies, the Commission will not analyse the 
potential effects of such foreclosure.  
5.2.4.3.3. Conclusion  
(243) In light of the above, the Commission concludes that the Transaction does not give 
rise to serious doubts regarding its compatibility with the internal market because 
of foreclosure  concerning  tying or bundling strategies with regard to electronic 
guarding and alarm monitoring and response services for non-residential customers  
in Sweden, Finland, Norway, Belgium and the Netherlands. While the combined 
entity would likely have the incentive to engage in such foreclosure strategies, the Commission concludes that it would not have the ability to do so. In particular, the 
primary target of such practices, large non -residential customers, are likely to have 
countervailing buyer power, which would prevent the combined entity from 
successfully employing a foreclosure strategy that would negatively affect the 
quality or price of the services offered.  
6. C
ONCLUSION  
(244) For the above reasons, the European Commission has decided not to oppose the 
notified operation and to declare it compatible with the internal  market and with the 
EEA Agreement. This decision is adopted in application of Article 6(1)(b) of the Merger Regulation and Article 57 of the EEA Agreement .  
For the Commission  
 
 
(Signed)  
Margrethe VESTAGER  
Executive Vice -President  
                                                 
408  Responses to question s 20 and 20.1. of Questionnaires Q1- Q5 to Customers; Responses  to 
question 48 of Questionnaire Q6 to Competitors.  
409  Response to question s 20 and 20.1. of questionnaires Q1- 5 to Customers.  
410  Response to question 48 of q uestionnaire Q6 to Competitors.