Short answer: holding a dealer meeting is perfectly legal, discussing resale prices, discount rates or the division of territories and customers in that room is not. Article 4 of Turkish Competition Law No. 4054 prohibits agreements, concerted practices and trade association decisions between undertakings that aim at or result in restricting competition, and it does not require a signed document to do so. The sanction is taken straight out of revenue: Article 16 allows an administrative fine of up to 10 percent of the annual gross revenue generated in the financial year preceding the decision. Managers and employees found to have had a decisive influence on the violation can be fined separately, up to 5 percent of the fine imposed on the company. These are not theoretical numbers. According to Turkish Competition Authority figures, the Board issued 530 decisions in 2025 and imposed a total of 12.1 billion lira in fines, 4.7 billion of which landed on the food sector. What gets said backstage matters as much as what goes on the screen, because during a dawn raid the Authority looks at the event WhatsApp group and at the second phone in a manager's pocket. Below: where recommended pricing ends and imposition begins, why dealers in the same room count as competitors, the separate risk hiding in the HR session, how the fine is calculated, and how to build an agenda that survives scrutiny.
Are dealer meetings restricted? The risk comes from two relationships in one room
The meeting itself is ordinary commercial activity. The problem is that two different legal relationships sit in the same hall. The link between supplier and dealer is vertical, since the parties operate at different levels of the production or distribution chain. The link between the dealers themselves is horizontal, because they often sell the same product in the same region. Article 4 of Law No. 4054 prohibits agreements, concerted practices and association decisions between undertakings that have the object or effect of preventing, distorting or restricting competition. The same article lists the obvious cases: fixing purchase or sale prices directly or indirectly, sharing territories and customers, limiting supply. On the evidence side there is a rule that works in the Authority's favour. Even where no agreement can be proven, price movements, supply and demand patterns or operating territories that resemble those in markets where competition is restricted create a presumption of concerted practice. Once that presumption applies, the burden flips: the company has to demonstrate, on economic and rational grounds, that it did not act in concert. So seating three dealers from the same province at one table in a forty-dealer meeting is not purely a floor plan decision.
Can a supplier set the dealer's resale price?
Partly, and the distinction sits in the type of price. Communiqué No. 2002/2 on Vertical Agreements excludes from block exemption any restriction of the buyer's freedom to determine its own selling price, which makes fixed or minimum resale prices a hardcore restriction. Maximum prices and recommended prices remain possible, as long as pressure or incentives do not turn them into fixed prices in practice. The block exemption also carries a market share threshold. Communiqué No. 2021/4, published in the Official Gazette of 5 November 2021 (issue 31650), cut that threshold for the supplier's share in the relevant market from 40 percent to 30 percent and pushed agreements above it into individual exemption analysis, with a six month adaptation window for existing contracts. One decision shows how firmly this is applied: on 14 December 2023, in decision 23-58/1147-409, the Competition Board found that Uğur Soğutma Makinaları had interfered with its resellers' prices and imposed an administrative fine of 51,373,002.89 lira. In the Board's settled approach, resale price maintenance is a restriction by object, so it is treated as a violation regardless of whether any effect on the market can be shown.
Which sentences count as indirect price fixing?
The indirect methods recognised in Turkish vertical agreements practice sit uncomfortably close to the language of a normal dealer meeting. Setting the buyer's profit margin. Announcing the maximum discount that may be applied to the recommended price. Granting an extra rebate or bonus to dealers who stick to that price. Signalling that deliveries will be delayed, suspended or the contract terminated for those who do not. A "recommended only" line in the corner of a slide does not settle the question on its own; what matters is whether the dealer genuinely keeps the freedom to deviate. Three scenes come up again and again. A regional price table projected on the LED wall and read out row by row. A call from the stage asking dealers to report colleagues who undercut. A price commitment form handed round for signature at the end of the day. None of them requires a written agreement to generate evidence of a concerted practice.
Dealers are competitors: can information exchange alone be a violation?
It can. Three tests decide the risk: whether the information is forward looking or historical, whether it is company specific or aggregated, and whether it is already public. Planned price increases, discount calendars, target margins, lists of customers being quoted and capacity plans are high risk the moment they are shared in a room full of competitors. Historical, sector wide aggregated data usually sits on safer ground. The critical point is that nobody needs to agree to anything, because once a company knows what its rivals intend to do, its next decision is no longer treated as independent. There is a safe harbour for smaller players, but a narrow one. The De Minimis Communiqué No. 2021/3, published in the Official Gazette of 16 March 2021 (issue 31425), lets the Board decline to investigate where the parties' combined market share stays under 10 percent in agreements between competitors, or where each party stays under 15 percent in agreements between non competitors. Clear and serious violations such as price fixing are carved out of that relief. A small market share will not save a meeting where prices get discussed.
Why is the HR session a separate risk?
Because the Authority treats labour markets as their own front, and the fines there keep growing. In decision 23-34/649-218 of 26 July 2023, the Board found that 16 undertakings had breached Article 4 through no poach agreements and imposed fines totalling 151.148 million lira. A more recent file came from pharmaceuticals: decision 25-34/810-474 of 11 September 2025 fined 17 companies roughly 244.8 million lira. Two behaviours stood out, gentlemen's agreements not to hire each other's staff and HR managers circulating salary increase rates and benefit data by email. Competition Authority figures put labour market violations at 557 million lira of fines in 2025, high in the sector ranking. Two sentences surface constantly during dealer meeting coffee breaks: what are sales rep salaries running at in your region, and let us agree not to poach from each other. Both sit inside the same risk. The picture does not change for HR panels, dealer association gatherings or supplier forums attached to the main event.
How much is the fine, and how is 10 percent of turnover calculated?
The ceiling is in the Law, the method is in a regulation. Article 16 caps the fine at 10 percent of the annual gross revenue generated at the end of the financial year preceding the decision. The Regulation on Administrative Fines for Agreements, Concerted Practices and Decisions Restricting Competition and for Abuse of Dominance, published in the Official Gazette of 27 December 2024 (issue 32765), sets the starting rate by reference to how clear and serious the violation is and how severe the actual or likely harm was. Duration then scales it: one fifth for violations lasting one to two years, two fifths for two to three years, three fifths for three to four, four fifths for four to five, and a full doubling beyond five years. Aggravating circumstances such as recurrence, continuing the conduct after being notified of an investigation, or having a decisive influence on it, can raise the fine by up to another 100 percent. Individuals are counted separately: managers and employees with a decisive role face up to 5 percent of the fine imposed on the company. Procedural fines have a floor of their own. Communiqué No. 2026/1, published on 12 December 2025, raised the minimum fine under Article 16, first paragraph, by the 2025 revaluation rate of 25.49 percent, setting it at 302,484.86 lira for 2026.
Deleting the WhatsApp group during a dawn raid: a flat 0.5 percent
This fine runs independently of the underlying violation and its rate is fixed. Where an on site inspection is obstructed or made more difficult, the company is fined 0.5 percent of its annual gross revenue for the preceding financial year. Recent Board decisions show how narrowly that is read. At a concrete producer, WhatsApp conversations were cleared at 10.36 once the inspection had begun, and the group was exited at 10.37. At a food distributor, deletions by employees were treated as destruction of evidence. At a transport company, refusing to let inspectors examine a manager's second work phone counted as blocking access to potential evidence. All three ended in the same line item. The event side of this is concrete: the field team WhatsApp group for the dealer meeting, the email chain carrying draft slides, the audio recording and photos shared afterwards. All of it can become inspectable material. Deleting the group in a panic after the event does not close the problem, it opens a second fine.
How do you build a dealer meeting agenda that holds up?
One: gather the agenda and every presentation file into a single folder before the event, and run approvals from that folder. Two: flag the slides that mention price, discount, rebate, territory, customer or salary, because the risk concentrates in those few pages. Three: brief the host in writing, so that when a dealer shouts from the floor that they do not sell at that price, the person on stage already knows how to close the topic. Four: run the Q and A from questions collected in advance rather than an open microphone. Five: hand out written prompts for roundtable sessions, since a heading like how are prices in your region produces a pricing conversation nobody minutes. Six: treat the dinner and the cocktail as part of the meeting and plan seating accordingly. Seven: whoever opens the digital trail owns the archive, and temporary groups get closed properly once the job is done. If something was said that should not have been, there is a way back. A leniency application can give full immunity to the first applicant in cartel cases, and the settlement procedure under Article 43 of Law No. 4054 allows a reduction of up to 25 percent in the fine, applied between 10 and 25 percent under the Settlement Regulation. Everything here is general information, so have your competition counsel read the actual agenda. Tales Event is based in Istanbul and delivers dealer meetings, product launches, gala nights and opening ceremonies across Türkiye, handling stage, sound, lighting, LED screens and content production under one contract. Send us your date and headcount, and we will design the session structure, stage script and recording plan so they line up with what your legal team has approved.
Let's talk about your event
Tell us your idea and we will prepare the concept and quote.