1 
  EUROPEAN COMMISSION  
 
Brussels, 22.08.2018  
C(2018) 5676 final  
 
 
 
 
 To the notifying parties:  
Subject:  Case M.8984 - Hg/Vista/Allocate  
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 17 July 2018, the European Commission (the "Commission") received 
notification of a proposed concentration pursuant to Article 4 of the Merger 
Regulation by which HgCapital LLP ("Hg") and Vista Equity Partners ("Vista") 
acquire within the meaning of Article 3 (1)(b) and Article 3(4) of the Merger 
Regulation joint control over the whole of Allocate Software ("Allocate") by way 
of purchase of shares (the "Transaction")3. Hg and Vista are each a “Notifying 
Party” and together referred to as the “Notifying Parties” . Hg, Vista and Allocate 
are collectively referred to as "the Parties".  
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, suc h 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 Publication in the Official Journal of the Europea n Union No C 261 , 25.07.2018 , p. 16.  
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.  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omitted has been replaced by ranges of figures or a 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.  PUBLIC VERSION  
 
2 
 1. THE PARTIES  
(2) Hg is a private equity firm which invests mainly in Europe into technology and 
technology enabled service businesses. With investment offices in London and 
Munich, Hg manages investments on behalf of over 100 institutional investors 
including private and public pensions funds and insurance companies. A n umber 
of Hg’s portfolio companies provide IT services including business software.  
(3) Vista is a U.S. based private equity firm that is focused on investments in 
software, data and technology -enabled businesses led by management teams with 
long-term perspecti ve. 
(4) Allocate is a portfolio company of Vista. Allocate is a provider of workforce and 
risk management software primarily to the healthcare industry. Its core product is 
used for workforce rostering and associated compliance workflows such as 
monitoring and  reporting on safe staffing levels.  
2. THE CONCENTRATION  
(5) The Transaction relates to the acquisition of joint control over Allocate by limited 
partnerships managed by Hg Pooled Management Limited, a subsidiary of Hg, 
and Vista.  
(6) Allocate is currently solely controlled by Vista, which holds 100% of the shares in 
Allocate Investor Holdco Limited. Pursuant to an option deed dated 20 April 2018 
(the "Option Deed"), Vista granted certain Hg funds a unilateral, non -transferrable 
and irrevocable option (the "Option" ) to subscribe for the Company Shares (as 
defined in the Option Deed) in an amount corresponding up to a 50% 
shareholding, exercisable during a six -week period following 16 May 2018. On 23 
May 2018, Hg exercised the Option. The purchase of the shares is su bject to 
customary regulatory conditions, including the approval by the Commission under 
the Merger Regulation.  
(7) Upon completion of the Transaction, the shareholdings in Allocate Investor 
Holdco Limited will be as follows:  
 Vista (aggregate of funds): 50% ;  
 Hg (aggregate of funds): 50%.  
(8) [Details on governance rights of Allocate].  
(9) The Notifying Parties will also have customary consent rights over key strategic 
decisions of Allocate, such as [Details on governance rights of Allocate]. These 
decision s will requi re the consent of both Notifying Parties prior to being 
undertaken. Each Notifying Party will enjoy a veto right over the adoption of key 
strategic decisions.  
(10) Therefore, the Transaction will result in the acquisition of joint control by Hg and 
Vista over Allocate.  
(11)  Post-Transaction Allocate will be a joint venture performing on a lasting basis all 
the functions of an autonomous economic entity. In particular, Allocate owns 
 
3 
 sufficient resources to operate independently on the market; it will not t ake over a 
specific function within the business activities of Vista and/or Hg; it does not and 
will not in the future rely on substantial sales or purchases between itself and 
either Hg, Vista or any of their portfolio companies; and it is intended to ope rate 
on a lasting basis with no fixed term or duration in the agreements between the 
parent companies.  
(12)  Therefore, the Transaction constitutes a concentration within the meaning of 
Article 3(1)(b) and Article 3(4) of the Merger Regulation.  
3. EU DIMEN SION  
(13)  The undertakings concerned have a combined aggregate world -wide turnover of 
more than EUR 5 000 million4 (Hg: EUR  […]; Vista: EUR […]; Allocate: EUR 
62.69 million ). Each of at least two of them has an EU -wide turnover in excess of 
EUR 250 million (Hg: EUR  […]; Vista: EUR […]; Allocate: EUR […]), but 
they do not achieve more than two -thirds of their aggregate EU -wide turnover 
within one and the same Member State.   
(14)  The notified operation therefore has an EU dimension pursuant to Article 1(2) of 
the Merger Regulation.  
4. RELEVANT  MARKETS  
4.1. Product market definition  
(15)  The Commission has previously assessed the market for business software5. In 
Oracle/PeopleSoft6, the Commission noted that the business software market 
(distinguished from consumer software) could be broadly categorized into 
infrastructure software and application software. The Commission specified that 
business application softwar e comprises software programs that address some 
aspects of planning, execution or collaboration in a business, government or other  
organization. These applications can in general be divided into (i) personal 
productivity applications and (ii) enterprise ap plication software ("EAS").  
 
4 Turnover calculated in accordance with Article 5 of the Merger Regulation.  
5 M.3216 Oracle / PeopleSoft (2004); M.3978 Oracle / Siebel (2005); M.4944 SAP / Business Objects 
(2007); M.4987 IBM / Cognos (2008); M.5763 Dassault  Systemes / IBM DS PLM Software business 
(2010).  
6 M.3216 Oracle / PeopleSoft (2004).  
 
4 
 (16) EAS is a segment of business software that supports the major business functions 
needed to manage a business effectively at a corporate or branch leve l, such as 
managing corporate finances, automating the sales and marketing functions of a 
company, or managing the resources involved in corporate projects.  
(17) The Commission further underlined that industry analysts generally distinguish 
various categories o f EAS. EAS can be further sub -segmented into Enterprise 
Resource planning ("ERP")7, Customer Relationship Management ("CRM") and 
Supply Chain Managem ent ("SCM"). ERP encompasses applications that manage 
the optimal use of enterprise resources such as emplo yees, assets and finances.8 
While CRM automates customer -facing business functions such as sales, 
marketing or call centers, SCM automates the planning production and delivering 
of goods and services.9  
(18) In turn, ERP encompasses a number of sub -categories. Those sub -categories are 
human capital management ("HCM") software and Financial Management 
software ("FMS"). HCM includes applications that automate one or more human 
resources functions of an enterprise, such as personnel management, benefits 
administrat ion, payroll, recruiting, employee development (such as training and 
succession planning) and performance analysis and review. FMS consists of 
applications allowing companies to maintain their general ledger, balance books, 
or prepare analytics and reports .10  
(19) The Notifying Parties take the view that the relevant product market encompasses 
all EAS solutions because of the significant degree of supply side substitutability 
from suppliers already operating across the EAS spectrum, such as SAP, Oracle 
and Sale sforce. Moreover, the Notifying Parties submit that there are numerous 
suppliers that are capable of expanding and diversifying their spectrum including 
Sage, Microsoft or Workday. Lastly, the Notifying Parties note that barriers to 
supply side switching a re not significant, specifically for small and mid -market 
customer segments.11  
(20) The responses to the market investigation in this case did not provide any new 
elements that would contradict the view of the Parties that there is no need to 
further subsegment the market of EAS. Given that in some previous Commission 
decisions, the market of EAS was further sub -segmented, the Commission has 
also assessed the segment of ERP for the purpose of this decision.12  
7  M.3216 Oracle / PeopleSoft (2004).  
8  See Form CO, paragraph 79 (a).  
9  See Form CO, paragraph 79 (b) -(c). 
10  See Form CO, paragraph 79 (b) -(c). 
11  See Form CO, paragraph  80. 
12  See M.3978 Oracle / Siebel (2005).  
 
 
5 
 (21) However, the relevant product market definition can be left open  for the purpose 
of this Decision as the Transaction does not give rise to serious doubts under any 
plausible sub -segmentation of the EAS market (namely ERP and HCM where the 
Parties' activities overlap).  
4.2. Geographic market definition  
(22) The Commission ha s previously considered that markets for business 
software/EAS solutions were at least EEA -wide and possibly worldwide.13 
However, as the Notifying Parties’ activities in the UK, Sweden and Denmark 
appear to be relatively concentrated, the Commission has a lso assessed these 
national markets separately for the segments ERP and HCM.14  
(23) The Notifying Parties take the view that the geographic market for EAS solutions 
is worldwide.  
(24) As stated in (22), in previous Commission decisions, the market for business 
software or for EAS solutions was at least EEA -wide or possibly worldwide.15 
Overall the responses to the market investigation in this case did not provide any 
new elements justifying a departure from the Commission's previous decisions.  
(25) In any event, the relevant geographic market definition can be left open for the 
purpose of this Decision as the Transaction does not give rise to serious doubts 
under any plausible geographic market definition (national, EEA or worldwide) 
for EAS and its sub -segmentations.  
5. COMPETITIVE ASSESSMENT  
(26) The Transaction gives rise to horizontal overlaps between the activities of the 
Parties in the provision of business software, where Allocate and certain portfolio 
companies of both Hg and Vista are active. Within the business so ftware sector, 
the horizontal overlaps exist within the market for EAS, and in particular in the 
ERP segment where Allocate is primarily active.  
(27) Within ERP, Allocate’s offering falls primarily into the provision of HCM 
software with a particular focus on s olutions for the healthcare industry. None of 
Hg or Vista portfolio companies focuses almost exclusively on the healthcare 
industry, with the exception of Greenway Health, which is not active in the EEA.  
5.1. Provision of ERP  
(28) The Notifying Parties provided  market shares on the basis of IDC and Gartner 
(independent providers of industry data) for ERP at worldwide, EEA and national  
13  M.5904 – SAP/SYBASE (2010); M.4944 SAP / Business Objects (2007); and M. 3978 Oracle / Siebel 
(2005).  
14  For more details, please refer to Section 5 below.  
15  M.5904 – SAP/SYBASE (2010); M.4944 SAP / Business Objects (2007); and M. 3978 Oracle / Siebel 
(2005).  
 
6 
 level in the Member States where their activities overlap. As shown in Table  1, in 
the ERP segment, the Parties' combined market shares exceed 20% at worldwide 
and EEA level, as well as in Denmark, Sweden and the UK.  
Table 1: ERP market shares for 2017  
  Worldwide  EEA  Denmark  Sweden  UK 
Gartner  
Hg [0-5]% [10-20]%  [20-30]%  [50-
60]%  [5-10]%  
Vista  [10-20]%  [10-20]%  [0-5]% [0-5]% [20-30]%  
Allocate  [0-5]% [0-5]% [0-5]% [0-5]% [0-5]% 
Combined  [20-30]%  [20-30]%  [30-40]%  [50-
60]%  [30-40]%  
IDC 
Hg - [5-10]%  [10-20]%  [30-
40]%  [5-10]%  
Vista  - [5-10]%  [0-5]% [0-5]% [10-20]%  
Allocate  - [0-5]% [0-5]% [0-5]% [0-5]% 
Combined  - [10-20]%  [20-30]%  [40-
50]%  [20-30]%  
Source: Form CO  
5.1.1. Notifying Parties' views  
(29) The Notifying Parties consider that the horizontal overlap between the Parties on 
the ERP segment raises no competition concerns.  
(30) The Notifying Parties consider that the combined market share of the Parties on 
the ERP worldwide and EEA -wide market is low and that the market share 
increment brought by Allocate is de minimis . 
(31) Additionally, the Notifying Parties submit that no  competition concerns arise on 
the basis of the post -merger HHI and HHI delta at the EEA and worldwide levels.  
(32) Further, according to the Notifying Parties Allocate has a particular focus on 
ERP/HCM solutions for the healthcare industry. Therefore, it does not compete 
closely with any of Hg or Vista portfolio companies, none of which focuses 
almost exclusively on the healthcare industry.  
(33) Finally, the Notifying Parties submit that their main competitors have 
considerable shares and will continue to constrain the Notifying Parties and there 
are a number of large international competitors that could easily increase their 
market presence further in response to any future hypothetical price increases.  
 
7 
 5.1.2. Commission's a ssessment  
5.1.2.1. Worldwide and EEA -wide  
(34) The Commission considers that the Transaction does not raise serious doubts as to 
its compatibility with the internal market in the market for the provision of ERP, 
at worldwide and EEA level, for the following reasons:  
(35) First, the Notifying Parties' portfolio companies have a combined share of [20-
30]% on the worldwide market and [20-30]% on the EEA -wide market based on 
Gartner data in 2017. Based on the IDC data of the same year, the EEA -wide 
market shares are a t [10-20]%.16  
(36) Second, the market share increment17 brought about by the Transaction is only [0-
5]% on a worldwide level and [10-20]% in the EEA in 2017 based on the Gartner 
data and [5-10]% in the EEA based on the IDC data.  
(37) Third, ERP is characterised by the presence of a large number of competitors. In 
the worldwide market for ERP, SAP, Oracle, Workday, Sage, Infor and 
Microsoft have market shares of [20-30]%, [10-20]%, [5-10]%, [5-10]%, [0-5]% 
and [0-5]%, respectively. In t he EEA, SAP is the market leader with a share of 
[20-30]%, while Sage, Microsoft, Oracle and Infor have market shares of [10-
20]%, [5-10]%, [5-10]% and [0-5]%, respectively.  
(38) Fourth, a majority of respondents to the market investigation either expressed a 
positive or neutral view in relation to the impact of the Transaction on ERP 
worldwide or in the EEA18. 
5.1.2.2. National level  
(39) The Commission further considers that the Transaction does not raise serious 
doubts as to its compatibility with the internal market in the market for the 
provision of ERP, at the level of Denmark, Sweden and the UK, for the following 
reasons:  
(40) With regard to Denmark, the Parties have a combined market share in 2017 of 
[30-40]% based on Gartner data and on [20-30]% based on IDC da ta. The market 
share increment brought about by the Transaction is only at [0-5]% for Gartner 
data and at [0-5]% for IDC data, respectively. Other competitors in ERP in 
Denmark include Microsoft, SAP, Infor and Oracle, with market shares of [30-
40]%, [20-30]%, [0-5]%, and [0-5]%, respectively.   
16     IDC data on worldwide level for ERP was not available.  
17  Increment being understood as the smallest of either the market shares of Hg (new controlling parent) 
or the combined market share of Allocate and its existing parent, Vista.  
18  Replies to Questionnaire Q1 to market participants of 19 July 2018, question 2. One respondent 
mentioned that it would have a negative impact in the EEA and clarified that the impact would be 
mainly on the Nordic market. The Comm ission has addressed this concern in Section 5.1.2.2.  
 
 
8 
 (41) With regard to the UK, the Notifying Parties have a combined share in ERP of 
[30-40]% based on Gartner data and on [20-30]% based on IDC data for the 
business year 2017. The market share increment brou ght about the Transaction is 
only at [5-10]% based on Gartner data on [5-10]% based on IDC data. Other 
competitors in ERP in the UK include Sage, SAP, Oracle, Workday and Microsoft 
with ERP market shares of [10-20]%, [10-20]%, [10-20]%, [10-20]% and [0-5]% 
respectively. Each of these competitors has the financial capability and industry 
expertise to readily expand their offering in the UK opportunistically.  
(42) With regard to Sweden, the Parties' combined share for the business year 2017 is 
[50-60]% based on Gartner data and is [40-50]% in ERP based on IDC data.19 
However, the market share increment brought about by the Transaction in Sweden 
is only at [5-10]% based on Gartner data and at [0-5]% based on IDC data. The 
Notifying Parties’ main competi tors in ERP in Sweden are large and sophisticated 
international companies. SAP, the European market leader, as well as Unit 4, Infor, 
Microsoft and Oracle have ERP market shares of [10-20]%, [5-10]%, [0-5]%, [0-
5]% and [0-5]% respectively. Each of these co mpetitors have the financial 
capability and industry expertise to readily expand their offering in Sweden.20 
Moreover, some competitors with sizeable worldwide and European -wide market 
shares that currently have a smaller presence in Sweden could further e xpand their 
[…]* in Sweden in ERP. These companies include Workday ( [0-5]% Sweden, [0-
5]% EEA -wide and [5-10]% worldwide) and Kronos ( [0-5]% Sweden, [0-5]% 
EEA -wide and [0-5]% worldwide). In particular, Workday, a US -based company, 
has significantly expanded its […]** in Europe in the last 5 years and has 
increased its market shares of ERP in Sweden fivefold since 2015. 21 Moreover, 
there is at least one internationally active  company which, albeit currently not 
active in ERP on the Swedish market, is a very strong ERP player in […]*** 
markets and could easily expand its footprint into Sweden: Sage has a market share 
of [20-30]% in France and of [10-20]% in the UK in 2017 ( [10-20]% EEA, [5-
10]% worldwide).  
(43) Finally, a majority of respondents to the market investigation either expressed a 
positive or neutral view in relation to the impact of the Transaction on ERP in the 
EEA.22 With regard to the Swedish market, the majority of r espondents also had 
either a positive or neutral view regarding the effects of the Transaction on ERP.23  
19  The Commission notes that the combined market  [should read: share ] in previous years has been lower 
based on Gartner data. In 2015 it has been at [40-50]% and in 2016 it was at [50-60]%. 
20  See Section IV. A.1 of the Form CO.  
* Should read: activities  
** Should read: activities  
21  Workday's market share in ERP in Sweden in 2015 was at [0-5]%. See Annex 12 to the Form CO.  
*** Should read: neighbourin g 
22  Replies to Questionnaire Q1 to market participants of 19 July 2018, question 2.  
23  Replies to Questionnaire Q1 to market participants of 19 July 2018, question 5. Two respondents raised 
concerns regarding the effects of the Transaction on the Swedish market including the concern that the 
Parties’ product offering in Sweden may become less specialized. The Commission has addressed these 
comments in Section 5.1.2.2.  
 
 
9 
 5.2. Provision of HCM  
(44)  In the HCM segment, the Parties' combined market shares are 20% or more at 
EEA level, as well as in Denmark, Sweden and the UK. However, the Transaction 
does not give rise to an affected market at worldwide level.  
Table 2: HCM Market shares for 2017  
  Worldwide  EEA  Denmark  Sweden  UK 
Gartner  
Hg [0-5]% [10-20]%  [30-40]%  [40-
50]%  [10-20]%  
Vista  [0-5]% [0-5]% [0-5]% [0-5]% [0-5]% 
Allocate  [0-5]% [0-5]% [0-5]% [5-10]%  [5-10]%  
Combined  [5-10]%  [20-30]%  [30-40]%  [50-
60]%  [20-30]%  
IDC 
Hg - [10-20]% [10-20]%  [30-
40]%  [5-10]%  
Vista  - [0-5]% [0-5]% [0-5]% [0-5]% 
Allocate  - [0-5]% [0-5]% [5-10]%  [5-10]%  
Combined  - [10-20]%  [10-20]%  [40-
50]%  [10-20]%  
Source: Form CO  
5.2.1. Notifying Parties' views  
(45) The Notifying Parties consider that the horizontal overlap in a hypothetical HCM 
sub-segment raises no competition concerns for the following reasons:  
(46) The Notifying Parties submit that their portfolio companies have low combined 
market shares on the worldwide and on the EEA -wide market, and Allocate’s 
worldwide and EEA  shares represent a de minimis market share increment.  
(47) Further, the Notifying Parties submit that the post -merger HHI and HHI delta at 
the EEA -wide and worldwide level confirm that the Transaction does not raise 
any competition concerns.  
(48) Finally, the Notif ying Parties submit that their main competitors have larger 
market shares in the worldwide market and the EEA level.   
 
 
10 
  
5.2.2. Commission's assessment  
5.2.2.1. Worldwide and EEA -wide  
(49) The Commission considers that the Transaction is unlikely to raise serious doubts 
as to its compatibility with the internal market in the market for the provision of 
HCM, at worldwide and EEA level for the following reasons:  
(50) First, the Notifying Parties' portfolio companies have a combined share of only [5-
10]% on the worldwide market and [20-30]% on the EEA -wide market based on 
Gartner data in 2017. Based on the IDC data, the EEA -wide market shares are 
even lower at [10-20]%.24  
(51) Second the market share increment brought about  by the Transaction is only [0 -
5]% on a worldwide level and [0 -5]% in the EEA in 2017 based on the Gartner 
data and is at [0 -5]% in the EEA based on the IDC data.25  
(52) Third, the Parties’ main competitors have larger market shares. In the worldwide 
market, SAP, Oracle, Workday and Kronos have  market shares of [10-20]%, [10-
20]%, [10-20]% and [5-10]% respectively. At the EEA level, SAP is the leading 
HCM supplier with a market share of [20-30]%, while Oracle, Sage and Workday 
have substantial market shares of [5-10]%, [5-10]% and [5-10]% respec tively.  
(53) Fourth, during the market investigation a majority of respondents expressed either 
a positive or neutral view on the impact of the Transaction on the HCM segment 
explaining that there are many competitors in the HCM segment. 26 
5.2.2.2. National le vel 
(54) The Commission considers that the Transaction does not raise serious doubts as to 
its compatibility with the internal market in the market for the provision of HCM, 
at the level of Denmark, Sweden and the UK, for the following reasons:  
(55) With regard to Denmark, the Parties have a combined market share for HCM in 
2017 of [30 -40]% based on Gartner data and on [10 -20]% based on IDC data. The 
market share increment brought about by the Transaction is only at [0 -5]% for 
both Gartner and IDC data, respectively . Other competitors in HCM in Denmark 
include SAP, Microsoft, Oracle and Deltek, with market shares of [30-40]%, [10-
20]%, [5-10]%, and [0-5]%, respectively.  
 
 
 
24     IDC data on worldwide level for HCM was not available.  
25     IDC data on worldwide level for HCM  was not available.  
 
26  Replies to Questionnaire Q1 to market participants of 19 July 2018, question 3. One respondent 
mentioned that it would have a negative impact in the EEA and clarified that the impact would be 
mainly on the Nordic market. The Commi ssion has addressed this concern in Section 5.2.2.2.  
 
 
 
11 
 (56) With regard to the UK, the Parties’ combined market share in 2017 based on 
Gartner data is at [20 -30]% and at [10 -20]% based on IDC data. The market share 
increment brought about by the Transaction in the UK for HCM is at [ 5-10]% for 
Gartner data and at [5 -10]% for IDC data, respectively. Other competitors in 
HCM  in the UK include Workday, SAP, Oracle and Sage, with market shares of 
[20-30]%, [10 -20]%, [10 -20]%, and [5 -10]%, respectively.  
(57) With regard to  Sweden, the Parties' combined share for the business year 2017 is 
[50-60]% based on Gartner data and [40 -50]% in HCM based on IDC data for the 
same business year.27 The market share increment brought about by the 
Transaction in the Sweden for HCM is at [ 5-10]% for Gartner data and at [ 5-10]% 
for IDC data, respectively. The Notifying Parties’ main competitors in HCM in 
Sweden are large and sophisticated international companies. SAP, Unit 4, Oracle, 
Workday and Kronos, have market shares of [10-20]%, [5-10]%, [5-10]%, [0-5]% 
and [0-5]% respectively. Each of these competitors have the financial capability 
and industry expertise to readily expand their offering in Sweden 
opportunistically. In particular, Workday, a US -based company, has significantly 
expanded i ts […]* in Europe in the last 5 years and has almost quadrupled its 
market shares of HCM in Sweden since 2015.28 Moreover, some competitors with 
sizeable worldwide, European -wide, or […]** regions' market shares that 
currently have a smaller presence in Sw eden could further expand their […]*** in 
Sweden in HCM. These companies include Microsoft ( [0-5]% Sweden, [10-20]% 
Denmark, [0-5]% EEA -wide and [0-5]% worldwide) and Cornerstone ( [0-5]% 
Sweden, [0-5]% Denmark, [5-10]% in UK, [5-10]% in France). Moreover, at least 
one internationally active company that is currently not active in HCM on the 
Swedish market is a strong HCM player in the neighbouring  markets and could 
easily expand its footprint into Sweden: Sage has a market share of [10-20]% in 
France and of [5-10]% in the UK in 2017 ( [5-10]% EEA, [0-5]% worldwide).  
(58) Finally, a majority of respondents to the market investigation either expressed a 
positive or neutral view in relation to the impact of the Transaction on HCM in the 
EEA.29 With regard to the Swedish market, the majority of respondents also had 
either a positive or neutral view regarding the effects of the Transaction on 
HCM.30   
 
 
 
27  The Commission notes that the combined market share in previous years has been lower based on 
Gartner data. In 2015 it has been at  [50-60]% and in 2016 it was at [50 -60]%.  
 *   Should read : activities  
28   Workday's market share in HCM in Sweden in 2015 was at [0-5]%. See Annex 12 to the Form CO.  
**  Should read : neighbouring  
*** Should read : activities  
29  Replies to Questionnaire Q1 to market participants of 19 July 2018, question 3. One respondent 
mentioned that it would have a negative impact in the EEA and clarified that the impact would be 
mainly on the Nordic market. The Commission has addressed this concern in Section 5.2.2.2.  
30  Replies to Questionnaire Q1 to market participants of 19 July 201 8, question 6. One respondent raised 
concerns regarding the effects of the Transaction on the Swedish market for HCM stating that the new 
entity may become “too dominant ”. The Commission has addressed the concerns of dominance at 
Section 5.2.2.2.  
 
12 
  
6. CONCLUSION  
(59) 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 Member of 
the Commission