Press Release 01/2025
February 19, 2025

The Portuguese Competition Authority (AdC) has fined three companies of the multinational technology consulting group Inetum a total of €3,092,000 for engaging in anti-competitive practices in the labour market over a period of, at least, seven years.

The Investigation
The investigation began in March 2022 after the AdC identified evidence suggesting that several companies, including Inetum Group, had entered into bilateral no-poach agreements.
These agreements involved a mutual commitment between companies not to recruit and/or make unsolicited offers to employees of the participating firms.
According to the AdC’s investigation, Inetum Group was a party to such agreements from at least March 2014 to August 2021.
On 27 May 2024, the AdC issued a Statement of Objections against the company directly involved in the anti-competitive conduct, as well as its parent companies.
As part of the same investigation, the AdC had previously sanctioned three other companies operating in the same market—two multinational firms and one national technology consulting company—for similar conduct between 2014 and 2022. The total fines imposed amounted to €4,082,000, a figure reduced due to the cooperation these companies provided during the investigation.
These three companies opted for the settlement procedure by cooperating with the AdC, waiving their right to challenge the factual allegations, providing relevant evidence of the infringement, and voluntarily paying the fine.
The use of the settlement procedure allows for significant procedural efficiencies while still ensuring that companies engaging in anti-competitive conduct are penalised. One of these companies had also applied for leniency.

The Conduct in Question
The companies involved entered into no-poach agreements, mutually committing not to recruit and/or not to make unsolicited approaches to each other’s employees. By engaging in this conduct, they restricted competition in the labour market by dividing the supply of labour and limiting the mobility of affected professionals.
This is the second sanctioning decision issued in relation to restrictive labour market practices since the AdC began intervening in this area in 2020.
No-poach agreements are prohibited under competition law, as they restrict companies’ autonomy in setting their commercial conditions and directly harm workers by reducing their bargaining power, limiting job mobility, and consequently, restricting wage progression.
To prevent such practices, the AdC published a Report and a Best Practices Guide in September 2021, outlining recommendations to avoid the establishment of no-poach agreements.
Restrictive labour market practices negatively impact business competitiveness, worker welfare, and the national economy. For this reason, the AdC has reinforced its focus on this area, highlighting the fight against such practices as one of its Competition Policy Priorities for 2025.
The objective is to ensure the proper functioning of the labour market, thereby aligning the interests of citizens and the economy.

The Fines
The fines imposed by the AdC are determined based on the turnover of the companies in the affected market during the period of infringement. Under competition law, fines cannot exceed 10% of the company’s turnover in the year preceding the decision.
When setting the fine amount, the AdC considers various factors, including the severity and duration of the infringement, the degree of involvement of each company, and the financial situation of the entities concerned.
Further details on the methodology used are available in the AdC’s Guidelines on the application of fines.