A business should be able to trace who decided to bid, how the price was calculated and who could access the offer. In the editorial team's view, the practical lesson from the funeral services cartel case is to examine this workflow before signing another set of documents.
What did the Competition Council find?
Latvia's Competition Council reported a cartel affecting 13 public procurements for funeral and related services. Fines total €47,124.66. The decision register distinguishes adoption on 1 October 2026 from publication on 20 October.
The decision fines eight companies; two were treated as one undertaking. The liquidated “Nacionālais Apbedīšanas Dienests” received no fine. An appeal is permitted within a month of entry into force. Whether one was filed by 22 October has not been verified.
Does a shared IP address automatically prove a cartel?
The Council assessed correspondence, bids and shared computer/IP use together. Our editorial conclusion: a technical match must not become a universal formula for proof. Managers should establish who accessed prices, why, and how that information influenced the company's conduct.
The Council's guidance for businesses also highlights risks involving shared advisers and employees. Outsourcing bid preparation calls for clear boundaries on information sharing.
What should you check before the next bid?
We recommend reviewing one selected tender file using these steps. This is a practical organisational method; a legal assessment of the specific circumstances remains necessary where relevant.
- The participation decision. Record the company's own reasoning: delivery capacity, required resources and commercial objective. Name the person responsible for approving the decision.
- The pricing rationale. Retain the cost calculation, assumptions and approved version. A reviewer should understand how the price follows from the company's own data.
- The access list. List employees and external providers who see the draft. Define the access each needs and when it should be reviewed.
- The adviser's assignment. Agree the scope, confidentiality and disclosure of potential conflicts in writing. If the adviser serves a competitor, assess whether tasks and information can be properly separated.
- The submission check. Compare the final file with the approved price and conditions. Record who submitted it and retain the submission receipt with that specific version.
- Reasons for changes. Where procurement rules permit withdrawing a bid or changing a price, prepare an independent explanation and approval. Check whether the decision reflects the company's own circumstances.
In a small team, one person may handle several tasks. We therefore recommend having at least the final price and submission file checked by another authorised colleague. Managers should appoint a backup in advance so that an urgent deadline does not make document handling difficult to track.
What if the review reveals a problem?
If a competitor's non-public pricing draft appears, we recommend preserving the original material and how it was received, stopping further circulation and involving the responsible manager. Discuss the next steps with a lawyer, including contact with the Council. Employees should already know where to report such a situation.
Test the procedure on a completed tender: can a colleague who was not involved reconstruct the decisions? If not, identify the missing document, responsible person and correction deadline. This exercise helps assess actual working practices rather than merely whether an instruction exists.
For separate administrative needs, explore Komercreģistrs services for businesses. When looking for an external provider, business listings can also help; assess the candidate's experience, assignment boundaries and potential conflicts before agreeing terms.
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