The Turkish Competition Board
("Board") imposed an administrative fine
on Biota Herbal Medicines and Cosmetics Laboratories Inc. and its
group companies (collectively, "Biota")
for submitting incorrect turnover information pursuant to Article
16/1(c) of the Turkish Competition Act No. 4054
("TCA").1
A. Background
On August 15, 2024, the Board conducted an on-site inspection at
Biota Herbal and imposed an administrative fine under Article
16/1(d) TCA for hindering the on-site inspection.2 Biota
submitted its consolidated turnover information for the year 2023
to the Board for determining the exact amount of the fine.
Subsequently, Biota applied for a settlement regarding the
alleged infringement subject to the investigation. During the
settlement process, upon the Board's request, Biota again
shared its turnover information for the year 2023 with the Board
for the determination of the fine to be settled. However, the Board
identified discrepancies between the
