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Published by ACODECO, 2017-08-30 12:12:13

Bulletin No. 12 - Free Competition

Bulletin No. 12 - Free Competition

Keywords: acodeco;,competition

Edition Nº 12
August, 2017

Promoting Free Competition
in the Media

Defending your freedom to compete

Of Our
Contributors - 2
Promoting Free

Projects - 3
Training at
Regional on
Competition Topics

Present - 4
with Judicial

In Numbers - 10
Main Costs of Private
Education, in Panama City,
Given the Current Situation

Free Competition


Free Competition

Promoting Free Competition

By: Harmodio A. Cedeño Espinosa
National Free Competition Director

In terms of free competition, the term "Competition
Advocacy" comes to develop and promote the actions or
tools that the Competition Authority has for education, in
order to promote a competitive culture and pro-competitive
environment. This functions and attributions fall within the
scope of article 86 of Law 45 of October 31, 2007 and which
are not only directed to economic agents or companies, but
also to associations, educational institutions, non-pro t
entities, Civil Society organizations and Public
Administration. It is through this law, that ACODECO may
recommend, through technical-legal reports, the adoption or
modi cation of any procedure or requirement speci c to any
sector of the national economy, as well as to carry out studies
to promote and strengthen the competition in the market.

This role of ACODECO has been exercised in the past, acting on its own initiative on many occasions and, at
others, at the request of a party, within the framework of article 3 of Law 45 of 2007, which states that the State
shall ensure that its decisions and administrative acts, the principles of free economic competition and free
competition shall be preserved, so that municipalities, autonomous institutions and institutions in general may
apply to ACODECO when, within the scope of its decisions, it may a ect free competition or consumer protection.

It is in this sense that ACODECO operates, always preserving the best interest of the consumer, so that any act,
meeting, agreement, arrangement, formula or formula aimed at violating free economic competition and free
competition in the production, processing, distribution, supply or commercialization of goods or services, is
analyzed and, if necessary, of advocacy work.

We are aware of ACODECO's competence to advocate for competition, since we have three departments in the
National Competition Directorate: the Department of Competition Research that investigates the commission of
all anti-competitive practices, the Department of Analysis and Market Studies that performs the economic
studies of the di erent markets of goods or services and the Department of Information and Price Veri cation
that performs surveys and price checks.

There departments detect the faults or distortions in the diverse markets of goods or services, so when there are
situations where there are monopolistic behaviors or when there are two competitors or more, which provide the
same or similar service. If there is no legal certainty of how that market operates or if such practice or behavior is
monopolistic, ACODECO may be asked to use its concept, through feasibility inquiries to determine whether a
particular action is pro-competitive or anticompetitive, or simply by ex-o ce, ACODECO, through its functions of
competition advocacy promotes free competition.

These functions of advocacy have been carried out before di erent governmental entities, among which we can
highlight the Social Security Fund, National Assembly of Deputies, Ministry of Agricultural Development, among

In the National Directorate of Free Competition we are committed to "Defend Your Freedom to Compete".


Free Competition
PANAMA the economic agents in this regard, AvCaOlidDaEcCióOnto redqeuestauamveanlidtoationdeof
Training at ACODECO in their respective areas. tmheateriinacleresasdee cionnsttrhuceciócnosyt unof
Regional on Competition It will also train o cials on subject c4o0n%strucdtieon mloasteriaclsonasnudm4id0o%reosf
Topics of the Resolution A-063-15 of July cuotnilsizuamroenrsnuuessetdroosuerviwcieobvíasewrveibce, ,
3, 2015, which establishes the saahvoinrrgántidmoeseantdietmrapnospyortcaotsiotonscodset.
ACODECO, through the National parameters and technical transporte.
Directorate of Free Competition , in procedures in which the ACODECO CLonssucmonesrsumhaidveorreesceihvaend nroetciicbeisdof
accordance with Law 45 of is based to verify the price increases in prices of construction
October 31, 2007 (Law 45), is adjustments due to the increase of mpraetceiroiasls bydedevemloapteerrsiafloers a todteal
responsible for initiating, ex o cio costs of construction materials, ratatBcpBAd4fehhmmuo4//,1gC7tOoc,o9ol3O0vcroD9fif2aia6nsó,EBs7l.B6hci9niCd.2prna10//eOai0.oc1..nadv1.rrd42seao9ue7e1dhml9sis4nea,d,ee,6s3amspwn2sd2dlaota0deo7aovorv.sren.2ntase1iecnt1uld1iodcidgnroviueeoastadqaotmflc4elueictedow4adoeosasl%nhmttludoaetiflacnooeoaossdnhrf,
or at the request of the party, This because the DNLC has the Owcreonwsnuwstlhu.taaemcdoiowddoeercbueosns.igtdeoeabohB.pfo/.ar2trho7ise4,t7pAh0aCe6rOa.9oD0nE.lloiCnsOe
investigations by the alleged Unit of Analysis of Costs Increase, iawEcponwpnllwaic.aaPptcRáiooOgdniYneEacfCoowTr.mgOeobSbv.dapIelNaidMlaatOiAoBCnIOL, IDAinRECIOtsOheSe.
commission of absolute and in charge of verifying or validating ftOPseuhonnRlellccOiceucnYioetaEtunnhmCdsteTrueadOm,oeeSneplvIlrfeNiaonrilMrssiemdoOaanfusocBaklirIalóeLmrdnIiiAod,itReeseoInnnOdpteSliirítsl.noypíevclaaiocdyandeeroedda,,
relative monopolistic practices, the increases of materials parafpccfUoeotdeooetalnrdlranmrosmsasrcosoweophuunnsvnilemlsnseaeaad,tgflzriloo:di,iod,raoatetdeerpdhcnconloaeoeétmrippcdlcteíuyynhliuccacmeooleciioalmanlaiefoo,reen.cdts,dInhaten,seorealapeedccamdioosmddnoipnniaretutleysioaniilscoculmttolicnmiatdifab,óaaettrnenabhhdrell,'deees
and apply the corresponding construction of new homes in itneitléiafol nop,urcchoarsreo agerlecetmróennitco anyd
sanctions. In addition, to learn order that they can guide to the amdodteinvodsa,daenl dreaclcaompoy. oEfnthaedicnicórneassee
about the processes of veri cation consumers and economic agents adjuntar los siguientes
of mergers in accordance with Law on the requirements to apply to documentos: copia de la cédula de
45, to conduct advocacy of the validation. Didireencttidcoadnsumer pbernseontasl: del
competition, technical notes and •vrccceeoooqrnmpiusieapcusardmtatTeihioidsnvenoeodrnt,oaatcnnawodedhpeinoitianrhilceecdrisoarepelulmogpcynhoersonneacottdeoruaets.rotnsodwadtehseob,ef,
consultations on feasibility with Online Application for the
the purpose of ensuring the Validation of the Increase in
process of free economic
competition and free competition, the Cost of Construction
to preserve the superior interest of Materials for New Homes
the consumer.
The ACODECO, from January to
The DNLC, aware of the July 2017 has received one
importance of combating hundred and thirty-two (132)
monopolistic practices and other validation requests for increase in
restrictions on the e cient cost of construction material for
functioning of the market for new housing, of which one
goods and services, has as a hundred twenty-four validation
project to train o cials of the (124) have been requests by
regional o ces of our institution consumers and eight (8) requests
on tools to prevent and combat
such practices, such as Leniency representing consumers saving time
Program, consultation on and money in transportation.
feasibility, judicial and extrajudicial
transactions, etc., in order to guide •t•neeacmesoidfPEalealdrwscooynendrasseluiazmendidadpoeaerctrotsnenonoontmiatoireinssnetseb. ylaaa

for prior validation by economic respuesta a la solicitud se hace vía
agents. web, representando a los
It should be noted that, by 2017, consumidores ahorro de tiempo y
60% of consumers have personally dinero.
approached the o ces of • Atención personalizada por
un equipo de abogados y


PRESENT we can emphasize that the BULLETIN
Magistrates have considered Free Competition
Non-Compliance with Judicial important aspects, that next we PANAMA
Settlements quote, such as:
- Neither the text of the application why this collegiate Court decides to
As mentioned in previous bulletins, nor the settlement itself gives rise order the court of the rst instance
ACODECO led a formal complaint to the idea or intention that, in the to process the present process in
against four sugar companies for event of non-compliance with the compliance with the procedural
non-compliance with their judicial obligations agreed upon by rules governing the matter, giving it
settlements, a process that after the ACODECO with the economic the procedure provided for in Law
corresponding distribution was agents involved in the settlement, 45 of October 31, 2007 (Hereinafter
the agreed route was the executive. the Law).
led in the Ninth Circuit Court, Civil - The execution of the settlement This situation, according to our
Branch of the First Judicial Circuit was not dictated within the Process point of view, is in accordance with
Judicial of Panama, who, by means in which it was approved, since it the legal basis that the ninth court
of Order No. 148-16 of February 17, was led, once the settlement has used for the admission of the
2016, declared the default and been approved. The document did process, speci cally article 124,
issued a warrant of payment for the not agree to keep the process open numeral one of the Law, as a
sum of one hundred thousand for the duration of the settlement. substantive rule that exhaustively
dollar (B / .100,000.00) in favor of - Reviewing the settlement, in enumerates the cases that are of
the National Treasury by each of the Clause Six and Seventh, the exclusive jurisdiction and privative
defendant companies. Chamber observes that the of the civil courts specialized in the
The order for payment was procedure that is agreed in case of matter. This rule states that: "In
appealed by the legal a possible breach of the agreement matters of monopolistic practices,
representative of the defendant allows the ACODECO to institute a disputes arising as a result of
companies in order for the High judicial action with the object that individual and / or collective claims
Court to decide on the appeal and the Judicial Branch resolves to the arising from the application or
to revoke the decision of the court responsibility for failure of the interpretation of this Law".
of rst instance (Court Ninth). defendant given in relation to the With this decision of the Third High
By means of the Judgment of July obligations contracted in the Court, it is up to the court of rst
25, 2017, the Third Superior Court Agreement, with the usual instance to determine how far back
of Justice, in accordance with the imposition of a pecuniary sanction the process will proceed in order to
substantive and procedural for compensation; The latter aspect decide whether or not there was a
procedure in force, decides to that could be charged by the breach of the judicial settlement by
revoke Auto No. 148-16 of February executive within the regulatory the defendants. Serve as a guide for
17, 2016 issued by the Ninth Court body of competition. future judicial settlements that may
and orders it to print the - Since the settlement is an be carried out by ACODECO and
proceedings Provided for in the law agreement between the parties give us the light to consider that
for processes for monopolistic becomes a law among those subs- such situations or breaches may be
practices. cribed, so that the agreement must well known by civil courts
Analyzing the considerations be ful lled in such a way that, by specialized in the matter.
emitted by this Superior instance judicial decision, if applicable,
declare the breach of the
settlement approved; Respecting
due process.
These were some of the reasons


BULLETIN Panama violates the principle of PRESENT
Free Competition due process, arguing that the law is
PANAMA explicit regarding that there must su cient information about the
Action for Protection of be a prior resolution that allows for good or service to be acquired.
a material act. The Plenum of the Supreme Court
Constitutional Guarantees The ACODECO publishes of Justice considered that
information on its website based obtaining truthful, clear and
The Action for Protection of on article 88 of Law 45 of 2007, su cient information on the
Constitutional Guarantees led by which empowers it to publish characteristics and content of the
the rm Cubias & Fung, results of investigations into goods and services it acquires is a
representing Avance Urbano, SA, complaints, veri cations, and right enshrined at the
against the verbal order issued by complaints, in order to guide and constitutional level in article 49 and
the Administrator of the Consumer protect the interest of consumers. that the ACODECO publishes
Protection and Competition information with the purpose of
Protection Authority (ACODECO), guiding and protecting the interest
where information related to of consumers.
requests for material increase Lastly, the Court concluded by
veri cation was made public. stating that, since it was not
established that it a ected the
The constitutional activist argued In this case, the ACODECO only constitutional provisions referred
that the administrator's order to publishes the veri cation response to by the applicant, it merits failure
publish information on the notes where it is only re ected to correspond to the claim relied
veri cations of price increase of whether the increase was validated upon. As a result, the Chamber,
materials violates the law, since it or not, but the con dential DOES NOT RECEIVE the Action for
did not have a resolution that information of the economic Protection of Constitutional
would enable it to do so as agents is not disclosed. Guarantees led by the rm Cubias
established in article 48 of Law 38 A substantial duty of the ACODECO & Fung, representing Avance
of 2000 on procedure is that under the premise of Article Urbano, S.A.
administrative. 49 of the Political Constitution of
The plainti also argued that Article Panama and Law 45; ensure the COMEX has an approximate share
32 of the Political Constitution of best interests of the consumer, of three percent (3.0%).
providing clear, truthful and After 14 months of the takeover of
Comex Panama by PPG Industries,
Ex O cio Merger: PPG-COMEX Inc., we have not found any
evidence that a ects the
In July 2014, PPG Industries, a By virtue of the announcement of competition of paint brands in
global supplier of paints, the merger agreement between Panama. It is concluded that the
non-decorative coatings, optical the companies with presence in operation did not prevent the entry
products, specialty materials, glass Central America and Panama, the of new competitors and did not
and berglass and COMEX, a Authority of Consumer Protection a ect the existing rivalry.
Mexican painting manufacturer and Competition Defense There are currently eleven paint
with presence in Central America (ACODECO) initiates an ex o cio distributors competing in paint
and Panama, noti ed the Federal investigation, in order to determine distribution. The operation doesn’t
Economic Competition if the operation is compatible with unreasonably diminish, restrict,
Commission (COFECE, acronym in Law 45 of 2007 and if so, to hinder or impede free economic
Spanish) its intention to merge. challenge it before the courts of competition and free competition
justice. for similar, similar or substantially
related goods or services.
This transaction involved the According to information provided
acquisition by PPG Industries of the by Pinturas del Istmo, SA, a
Comex Group. The Commission Panamanian company engaged in
considered that the purchase of the marketing of COMEX-coated
Comex by PPG Industries would be paints, PPG Industries, Inc. through
unlikely to a ect competition and Pintuco, in the Panama market, has
free competition in Mexico. That is, a participation of approximately
there were no risks to competition thirty-two Percent (32.0%) and
in the markets analyzed.


Free Competition
markets ( re and liability) that search, for example, the acquisition
On October 15 2015, ACODECO, before the merger were below the of national companies by
through news published in the threshold of 0.25 and after the
newspaper La Prensa, learned of merger exceeded the threshold. transnational companies, the
the existence of the merger aggressive participation of
operation consisting of the Prior to the merger, four markets
acquisition of 100% of AIG (multi-risk, transport, hull and insurance companies in the
SEGUROS PANAMÁ, S.A., shares others), exceeded the threshold of
(Hereinafter AIG) by ASSA 0.25 that establishes the Guide for di erent trade and promotional
COMPAÑÍA DE SEGUROS, S.A. the Control of Mergers adopted by fairs of housing, cars and health.
(ASSA). Proceeding with an ex ACODECO. Also, the constant publicity
o cio veri cation, with the
purpose of knowing the e ects The Guide notes that when the maintained in the television and
that could have this operation of Index of Dominance has a value
merger within the insurance sector, greater than 0.25 (regardless of radio media, in websites, social
which constitutes a market whether it has increased or
regulated by the decreased) the merger assessment networks, with aggressive and
SUPERINTENDENCE OF INSURANCE with respect to relevant markets
AND REINSURANCE OF PANAMA. requires completing the following innovative promotions to attract
sections of the methodology,
After the analysis made with the barriers to entry and conditions of customers through the
objective of de ning the product rivalry in these markets.
market (substitutability) and the di erentiation of products, the
geographic market, it was possible In the analysis to determine the incorporation of the development
to determine that the relevant emergence of barriers to entry and of new platforms and technological
market constituted by each of the a ectations to the conditions of tools, have facilitated customers
types of insurance o ered within rivalry, derived from the mergers. It access to insurers 24 hours a day,
the geographic scope of the was observed that 30 insurance seven days a week and have
Republic of Panama. companies operate in the Republic contributed to the simpli cation of
of Panama, which is a high number the management processes
Regarding the structural conditions of national and foreign insurers performed by insurers, brokers and
of the relevant markets, we can o ering all branches and insurance agents.
mention that the dominance index sub-insurances, which have shown
(ID) re ected the existence of two that, in order to start operations, From the analysis of the merger
the requirements, including the operation, the National
minimum capital that must
constitute cash to start operations, Competition Authority concluded
are fully surmountable. that the common insurance

Within the insurance market in markets in which there was a
Panama, in recent years, there has change in the market structure,
been a constant dynamic in terms there was no limitation on the
of competition and leadership entry of potential competitors.

It was also concluded that the
transaction did not adversely a ect
the actual rivalry between the
economic operator resulting from
the merger and the other

participating economic operators
in the relevant markets.


Free Competition

Research by Absolute Monopolistic Practice in the purchase of Musical Instruments by the
National Assistance Program (PAN)

The Anti-Corruption Prosecutor's O ce of the Nation’s Attorney General's
O ce, put in knowledge of the ACODECO, about the brief followed in the

criminal jurisdiction. The brief relates acts of purchases of musical instruments
by the National Government through the National Assistance Program (PAN,
acronym in Spanish), to be distributed in schools at the national level for the
years 2013 and 2014 because it might exist at the same time, a possible

restrictive conduct of the competition. Which would be up to the National Directorate of Free Competition
(DNLC, acronym in Spanish), decide if it had merit to start an investigation.

From the brief that referred to us, was observed that in the processes of purchase of musical instruments for the
year 2013 (project No. 57696), involved the Economic Operators: NULATO COMERCIAL, INC., COUNTRY MAX,

Being the winner NULATO COMERCIAL, INC., while, for the year 2014 (project No. 58491), COUNTRY MAX, S.A.,

Despite the participation of several enterprises in government procurement acts, these acts are not governed
by Law 22 of 27 June 2006, which regulates public procurement in Panama and is of general application, but,
both acts were based on the Decree No. 690 Executive on July 22, 2010 which creates the PAN, i.e., special


Based on information and ndings in the administrative proceedings, it was found that the ve companies
participating in acts of purchase of musical instruments, belonged to the same economic group, in this case to
a single natural person. So, in accordance with article 9 of the Law 45 of 2007, which regulates the Economic
Competition in Panama – the ve participating companies, would have to be considered as a unit, i.e., as a
single economic agent participating in procurements acts.

According to article 13 of Law 45 of 2007, one of the presuppositions that had to be ful lled in order to establish
the existence of an unlawful absolute monopolistic practice is that the act, agreement or contract was made
between competing or potentially competing economic agents; Hence, since the ve companies participating
in the contracting acts, controlled by the same natural person, do not comply with the aforementioned budget;
and therefore, could not be shaped in any way, the existence of an unlawful absolute monopolistic practice.


Free Competition

High De nition Television (HD)

ACODECO, received a formal complaint on August 18, 2016 from the
company CABLE & WIRELESS PANAMÁ, S.A. (Hereinafter CWP) against the
companies TELEVISORA NACIONAL, S.A. (Hereinafter TVN),
CABLE ONDA, S.A. (CABLE ONDA), for the possible commission of
absolute and relative monopolistic practices.

Based on the documentation provided and the preliminary analysis of
the complaint led, the National Competition Authority (hereinafter DNLC) preliminarily considered that there
were indications of possible monopolistic practice, of refusal of treatment. Whenever CWP competitor of CABLE
ONDA on the Pay-TV service, questions the refusal of MEDCOM and TVN for failing to comply with its request to
include in its Pay-TV system the signals of its open channels in HD, while CABLE ONDA, its direct competitor can
include open HD TV signals on its pay TV system.

The DNLC, through Resolution No. DNLC-DVF-012-16 of October 13, 2016, orders the o cial opening of an
administrative investigation by the alleged commission of relative monopolistic practice, against TVN and
In the course of the investigation the complainant added information to the le indicating that CWP is transmitting
the signals in HD from MEDCOM and TVN, that MEDCOM signed an agreement to provide access to CWP and that
TVN is waiting to be able to sign a de nitive contract with CWP for the transmission of its channels of open
television in High De nition.

Finally, the DNLC, through Resolution No. DNLC-HCE-019-17 of august 16, 2017, ordered the closure of
administrative investigation No. PM-007-16 of August 18, 2016, due to a relative monopolistic practice against the
economic agents TVN and MEDCOM.

Research for absolute monopolistic practices in laundries

The Authority of Consumer Protection and Competition Defense (hereinafter referred to as ACODECO) initiated an
ex-o ce investigation concerning the possible commission of a restrictive practice of competition against some of
the laundries and lavatories located in the and District of San Miguelito, in the sector of Santa Librada and District
of Panama, Corregimientos of Juan Diaz, in the years 2014 and 2015 accordingly.

The DNLC through the Department of Price Information and Veri cation (DIPREV), made a tour of the mentioned
areas to collect the price information of the di erent establishments that provide the service of ironing and dry
cleaning. During the investigation, testimonial statements were taken from which it was noticed that the economic
agents preliminarily investigated maintained the same price of ironing, likewise, the economic agents declared
justi cation of the increase of the ironing, arguing increases of light, the water, the Price Of the local and the salary

of the workers who iron.

While it is true, and according to the allegations received, there appeared to be
prima facie evidence of an alleged monopolistic practice on the part of the
laundries and laundromats investigated, the ndings as a result of the
investigation indicate that there is no conclusive evidence Of Some type of act,
combination, arrangement and / or coordinated agreement between the
investigated companies that allow to sue before the specialized courts of free


Free Competition

Intergovernmental Group of Experts (IGE) on Competition Law and Policy,
Sixteenth Session

ACODECO participated in the c) Challenges faced by small and Berenguer presented the report
meeting held in Geneva, newly created Competition and the reviewers were Russell
Damtoft of the Federal Trade
Switzerland from July 5 to 7, 2017, Regulators, in the elaboration of a
where participating countries regime of merger control; Commission, United States; Paulo
discussed the following topics: Burnier da Silveira, Commissioner
The IGE, at roundtable, examined of the Administrative Council for
(a) Technical assistance and challenges being faces by small Economic Defense, Brazil and
and recent Competition
capacity building activities carried Alessandra Tonazzi, of the Italian
out: Regulators, in the creation of a Competition Authority.
regime of control of mergers
The IGE heard the exposure of the (TD/B/C.I/CLP/45); Conclusions
UNCTAD secretariat on the major
activities and projects in course of (d) Voluntary peer review of Reading of the agreed conclu-
execution, as well as exhibitions of Argentina’s Competition Law and sions. The UNCTAD secretariat was
the representatives of the Policies. ordered to prepare studies for the
next session on:
bene ciary countries and donor In accordance with paragraph 3 of
the agreed conclusions adopted • The challenges facing the
agencies. by the IGE at its 15th session, IGE developing countries in the
conducted a peer review of
(b) Strengthening of international Argentina’s Competition Law and regulation and competition in the
cooperation to investigate cases Policies, and published the full text maritime transport sector.
relating to cross-border of the report
(UNCTAD/DITC/CLP/2017/1). In • Issues of competition in the
competition: instruments and order to facilitate the debate on sale of audiovisual rights at major
procedures; the report, the IGE distributed a sporting events.
summary in all languages
The IGE examined, at round table, (TD/B/C.I/CLP/46). Representing
the strengthening of international UNCTAD, consultant Luis
cooperation in order to investi-
gate cases relating to cross-border

competition: instruments and
procedures. (TD/B/C.I/CLP/44)


Free Competition

Main Costs of Private Education, in Panama City, Given the Current Situation

The Ministry of Education, survey or monitoring of costs to Average 85.71% of the data of the
through Executive Decree No. various private schools with the schools of the sample.
601, of July 9, 2015, which purpose of informing consumers
in a timely manner of the We can assert that up to 86.44% of
regulates article 130 of the Single educational services o ered in the schools surveyed increased
Text of the Organic Law 47 of Panama City. their annuity for the 2018
academic year, depending on the
Education, dated September 24, ACODECO has conducted a non- level studied (in this case Primary).
1946, states in its article 2: probabilistic sampling of trials, in
which, based on an initial list of 50 Percentage of total increases in
“The Invitation to consider private schools in Panama City, to enrollment, in relation to the
changes in tuition costs, as well as which they have been sent a note sample:
costs and obtaining uniforms and requesting information from the
school supplies, in addition to survey om the annual costs of Pre-school 61.02% of schools in
proposing the annuity, should be registration (tuition) and tuition the sample (Kindergarten)
done by the private school, (annuity).
through the legal representative Primary 64.41% of the teaching
or the principal of the campus to The sample consisted of 50 centers of the sample
the parents of the family and to private schools that responded in
the coordinator of particular a timely manner with the Premedia 62.07% of the teaching
requested information on costs or centers of the sample
education of the respective investment in education for the
regional direction of education. 2018 academic year. Average 62.50% of the data of the
schools of the sample.
This call will be made in a timely Percentages of Total Increases in
manner, at least six (6) months Annuity, in relation to the sample: More than half of the sampled
before the beginning of the
enrollment period established by Pre-school 84.75% of schools in schools increased their
the school for the next school year the sample (kindergarten)
and its main objective will be to Primary 86.44% of the teaching enrollment for the 2018 school
coordinate changes in the tuition centers of the sample year.
cost, as well as everything related Premedia 84.48% of the teaching
to costs and obtaining uniforms centers of the sample
and school supplies and the


For its part, ACODECO conducts a


Free Competition

Annual Tuition
Table No.1



Details (in Balboas)
Primary (General Basic Education)

Teaching Center I II III IV V VI Average Cost Variation

Academia Hosanna 1,026.00 1,026.00 1,026.00 2018 2017 B/. %
Academia Bilingüe de San Lorenzo 1,210.00 1,210.00 1,210.00 1,026.00
Centro Educativo Bilingüe Central Belén 1,026.00 1,026.00 1,026.00 1,270.00 846.00 180.00 21.3
Centro Educativo Colinas de Las Cumbres 800.00 800.00 800.00 1,330.00 1,330.00 1,330.00
Centro Educativo El Buen Pastor Shalom 880.00 880.00 880.00 825.00 1,100.00 170.00 15.5
Centro Educativo Monte de Sion 950.00 950.00 950.00 850.00 850.00 850.00 880.00
Colegio Adventista Metropolitano 600.00 650.00 650.00 880.00 880.00 880.00 950.00 575.00 250.00 43.5
Colegio Anglo Mexicano 1,200.00 1,200.00 1,200.00 950.00 950.00 950.00 675.00
Colegio Bilingüe Abba Padre 1,920.00 1,920.00 1,920.00 700.00 700.00 750.00 1,200.00 - NA NA
Colegio Bilingüe de Cerro Viento 760.00 760.00 760.00 1,200.00 1,200.00 1,200.00 1,920.00
Colegio Bilingüe de Jesús de Praga 1,450.00 1,450.00 1,450.00 1,920.00 1,920.00 1,920.00 760.00 750.00 200.00 26.7
Colegio Bilingüe de Panamá 1,550.00 1,580.00 1,580.00 760.00 760.00 760.00 1,450.00
Colegio Bilingüe La Academia 1,950.00 1,950.00 1,950.00 1,450.00 1,450.00 1,450.00 1,575.00 495.00 180.00 36.4
Colegio Bilingüe Vista Hermosa 1,100.00 1,100.00 1,100.00 1,580.00 1,580.00 1,580.00 1,975.00
Colegio Brader 1,150.00 1,300.00 1,300.00 2,000.00 2,000.00 2,000.00 1,100.00 1,200.00 0.00 0.0
Colegio Claret Panamá 5,400.00 5,400.00 5,400.00 1,100.00 1,100.00 1,100.00 1,275.00
Colegio de Las Esclavas del Sagrado Corazón de Jesús 1,500.00 1,500.00 1,500.00 1,300.00 1,300.00 1,300.00 5,525.00 1,720.00 200.00 11.6
Colegio Internacional de María Inmaculada 2,400.00 2,400.00 2,400.00 5,650.00 5,650.00 5,650.00 1,500.00
Colegio Internacional Saint George de Panamá 2,200.00 2,200.00 2,200.00 1,500.00 1,500.00 1,500.00 2,400.00 660.00 100.00 15.2
Colegio Isaac Rabin 2,500.00 2,500.00 2,500.00 2,400.00 2,400.00 2,400.00 2,200.00
Colegio Javier 6,150.00 6,150.00 6,150.00 2,200.00 2,200.00 2,200.00 2,500.00 1,320.00 130.00 9.8
Colegio La Salle 2,370.00 2,370.00 2,370.00 2,500.00 2,500.00 2,500.00 6,166.67
Colegio Nuestra Señora de Bethlem 2,680.00 2,680.00 2,680.00 6,150.00 6,150.00 6,250.00 2,370.00 1,525.00 50.00 3.3
Colegio Nuestra Señora de Lourdes 1,900.00 1,900.00 1,900.00 2,370.00 2,370.00 2,370.00 2,680.00
Colegio Nuestra Señora del Carmen 1,400.00 1,400.00 1,400.00 2,680.00 2,680.00 2,680.00 1,900.00 1,825.00 150.00 8.2
Colegio Parroquial San Judas Tadeo 1,020.00 1,020.00 1,130.00 1,900.00 1,900.00 1,900.00 1,400.00
Colegio Pureza de María 1,050.00 1,050.00 1,050.00 1,400.00 1,400.00 1,400.00 1,130.00 900.00 200.00 22.2
Colegio Real de Panamá 1,900.00 1,900.00 1,900.00 1,130.00 1,240.00 1,240.00 1,050.00
Colegio San Agustín Panamá 3,950.00 3,950.00 3,950.00 1,050.00 1,050.00 1,050.00 1,900.00 1,191.67 83.33 7.0
Colegio San Vicente de Paúl 2,550.00 2,550.00 2,550.00 1,900.00 1,900.00 1,900.00 4,125.00
Colegio Santa Marta 1,550.00 1,550.00 1,550.00 4,300.00 4,300.00 4,300.00 2,550.00 5,175.00 350.00 6.8
El Colegio de Panamá 1,300.00 1,300.00 1,300.00 2,550.00 2,550.00 2,550.00 1,550.00
Escuela Bella Vista 5,000.00 5,000.00 5,000.00 1,550.00 1,550.00 1,550.00 1,300.00 1,300.00 200.00 15.4
Escuela Bilingüe Saint John 1,000.00 1,000.00 1,000.00 1,300.00 1,300.00 1,300.00 5,175.00
Escuela Franco Panameña Louis Pasteur 1,200.00 1,200.00 1,200.00 5,350.00 5,350.00 5,350.00 1,000.00 2,100.00 300.00 14.3
Escuela Particular Osiris 1,350.00 1,350.00 1,350.00 1,000.00 1,000.00 1,000.00 1,200.00
Escuela Montessori de Panamá 1,000.00 1,000.00 1,050.00 1,200.00 1,200.00 1,200.00 1,350.00 1,950.00 250.00 12.8
Escuela Panamá (Panama School) 2,750.00 2,750.00 2,750.00 1,350.00 1,350.00 1,350.00 1,033.33
Instituto Atenea 1,720.00 1,720.00 1,720.00 1,050.00 1,050.00 1,050.00 2,775.00 2,400.00 100.00 4.2
Instituto Bern 2,600.00 2,600.00 2,600.00 2,800.00 2,800.00 2,800.00 1,720.00
Instituto Bilingüe Andrés Bello 1,500.00 1,500.00 1,500.00 1,720.00 1,720.00 1,720.00 2,600.00 6,066.67 100.00 1.6
Instituto Bilingüe Cristo de Los Milagros (IBCM) 700.00 700.00 700.00 2,600.00 2,600.00 2,600.00 1,500.00
Instituto Bilingüe Internacional de Panamá 1,350.00 1,350.00 1,350.00 1,500.00 1,500.00 1,500.00 700.00 2,120.00 250.00 11.8
Instituto Bilingüe Santa María La Antigua (ISMA) 1,740.00 1,740.00 1,740.00 700.00 700.00 700.00 1,350.00
Instituto Comercial Ovidio De León 1,500.00 1,500.00 1,500.00 1,350.00 1,350.00 1,350.00 1,740.00 2,350.00 330.00 14.0
Instituto Cultural 1,125.00 1,125.00 1,125.00 1,740.00 1,740.00 1,740.00 1,500.00
Instituto de Ciencias Aplicadas 2,410.00 2,410.00 2,410.00 1,500.00 1,500.00 1,500.00 1,125.00 1,900.00 0.00 0.0
Instituto Episcopal San Cristóbal 1,925.00 1,925.00 1,925.00 1,125.00 1,125.00 1,125.00 2,410.00
Instituto Italiano Enrico Fermi 2,380.00 2,380.00 2,380.00 2,410.00 2,410.00 2,410.00 1,925.00 1,400.00 0.00 0.0
Instituto Justo Arosemena 3,130.00 3,130.00 3,200.00 1,925.00 1,925.00 1,925.00 2,365.00
Instituto Panamericano 1,980.00 1,980.00 1,980.00 2,350.00 2,350.00 2,350.00 3,176.67 1,030.00 100.00 9.7
Instituto Tecnológico Barú 1,945.00 1,945.00 1,945.00 3,200.00 3,200.00 3,200.00 1,980.00
Instituto Técnico Don Bosco 1,550.00 1,550.00 1,550.00 1,980.00 1,980.00 1,980.00 1,945.00 1,050.00 0.00 0.0
Instituto Williams H. Kilpatrick 1,500.00 1,500.00 1,500.00 1,945.00 1,945.00 1,945.00 1,550.00
Moisés Bilingual College 1,419.00 1,419.00 1,419.00 1,550.00 1,550.00 1,550.00 1,500.00 1,600.00 300.00 18.8
Panamerican School 1,200.00 1,200.00 1,200.00 1,500.00 1,500.00 1,500.00 1,419.00
Saint Joseph Salesian School 4,400.00 4,400.00 4,400.00 1,419.00 1,419.00 1,419.00 1,200.00 4,125.00 0.00 0.0
Smart Academy Panama 1,400.00 1,400.00 1,400.00 1,200.00 1,200.00 1,200.00 4,510.00
Oxford International School 3,150.00 3,150.00 3,150.00 4,620.00 4,620.00 4,620.00 1,400.00 2,300.00 250.00 10.9
The Oxford School (1) 4,025.00 4,025.00 4,025.00 1,400.00 1,400.00 1,400.00 3,175.00
TOTAL INFORMANTES PRIMARIA... 4,015.00 4,015.00 4,356.00 3,200.00 3,200.00 3,200.00 4,025.00 1,300.00 250.00 19.2
4,025.00 4,025.00 4,025.00 4,304.67
4,356.00 4,356.00 4,730.00 950.00 350.00 36.8
5,025.00 150.00 3.0

900.00 100.00 11.1

1,000.00 200.00 20.0

1,050.00 300.00 28.6

933.33 100.00 10.7

2,475.00 300.00 12.1

1,420.00 300.00 21.1

2,600.00 0.00 0.0

1,100.00 400.00 36.4

600.00 100.00 16.7

1,250.00 100.00 8.0

1,450.00 290.00 20.0

1,400.00 100.00 7.1

1,125.00 0.00 0.0

2,100.00 310.00 14.8

1,650.00 275.00 16.7

1,995.00 370.00 18.5

3,026.67 150.00 5.0

1,430.00 550.00 38.5

1,645.00 300.00 18.2

1,450.00 100.00 6.9

1,310.00 190.00 14.5

1,290.00 129.00 10.0

1,100.00 100.00 9.1

4,100.00 410.00 10.0

1,250.00 150.00 12.0

2,475.00 700.00 28.3

3,500.00 525.00 15.0

4,304.67 0.00 0.0

59 Datos comparables

(1): The costs for students enrolled from 2016 on wards are different. B/. %

N.A.= No Aplicable Promedio 229.85 15.9
Source: ACODECO Mínimo 0.00 43.5

Máximo 700.00 51
Without Variation

Percentage increases

National Directorate of
Free Competition

Obligation of the Public Servant

Report to the ACODECO those situations arising from public tenders when there are indications of:

Concealed positions, in which they can submit o ers and then withdraw them, or if there is the case of
incomplete proposals, requested and undelivered requirements.

Abolition of o ers or abstention to participate in a public tenders: Abstention to participate in a particular
area in order for the opponent to participate and win that area.

Winner rotation: When an economic agent wins an act, but in the next public act participates with the
purpose of losing so that its competitor wins.

Companies that present themselves as competitors in the homologation meeting and are subsequently
presented as consortia or accidental associations at the time of the submission of bids.

The winner of the public act subcontracts the losing economic agent.
The lowest bid is always submitted by the same economic agent, while the o ers of their opponents are
superior or costly.

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