1. Literature Review
[first set out briefly what the Coca Cola/SAB merger entailed – was it a horizontal merger? Vertical merger? Both? Then set out what your lit review will cover based on this.]
This chapter provides a review of the literature on horizontal and vertical mergers. It focuses specifically vertical mergers, and theories of harm resulting from vertical mergers and vertical restraints. It further discusses the empirical literature covering how other jurisdictions internationally have dealt with merger that have involved The Coca-Cola Company. Finally, this review will assess the different methods used in impact or ex-post assessments of competition interventions.
- Competition effects of vertical mergers and vertical restraints
A merger occurs when one or more firms directly or indirectly acquire or establish direct or indirect control over the whole or part of the business of another firm. It can be achieved through the purchase or lease of the shares, an interest or assets of the other firm in question and amalgamation or other combination with the other firm in question.
A horizontal merger is between parties that are competitors at the same level of production and/or distribution of a good or service, they are in the same relevant market (International Competition Network Merger Guidelines, 2006). When the two companies merge there is an elimination of rivalry between the overlapping activities of the merging parties which may lead to harm to or loss of competition. Horizontal mergers can make it profitable for the merged entity to unilaterally raise its price or reduce its output, post-merger. Furthermore, it can make it more likely or easier for the enterprises remaining in the market to coordinate, either tacitly or explicitly. The loss of a competitor during a horizontal merger can change the competitive incentives of the merging parties, their rivals and of their customers.
A vertical merger takes place between firms that operate at different but complementary levels in the chain of production (International Competition Network Merger Guidelines, 2006). Vertical mergers have significant potential to create efficiencies largely because the upstream and downstream products or services since they complement each other. On the other hand, vertical mergers may sometimes give rise to competition concerns. How vertical mergers affect competition has been a big debate in the history of antitrust. The Chicago School in the 1970s supported a perspective that vertical mergers offer the merging parties an opportunity to reap efficiencies, which may ultimately translate into greater competition in terms of prices and service for final consumers (Saggers, 2008). When firms are vertically integrated, the merged entities can align the profit-maximising incentives of producers at different production levels. Efficiencies are likely to occur through improved coordination of production. This is as a result of improved information flow and reduced uncertainty. The merged entities are likely to realise cost savings by planning more predictable supply of essential inputs and enhance product innovations due to synchronised research and development spending. Another efficiency arising from a vertical merger is the elimination of double marginalisation (Motta, 2004). In this case it is when a firm chooses an output level and mark-up over costs, it does this in order to maximise its own profits. However, due to the firm’s profit-maximising behaviour it then affects the profit-maximisation decisions of the other firms in the vertical chain. Furthermore, with both the upstream and the downstream firms adding their own margin, it then negatively affects the consumers since the final price they pay is higher than the price that would have been set had both firms jointly profit maximised and chosen a single mark-up. (add more references)
In the approved merger when assessing the anti-competitiveness, Post-Chicago theories of anticompetitive harm from a vertical merger focus on how foreclosure either raises rivals‘ costs or reduces rivals‘ revenues and how these negative effects on rivals result in anticompetitive harm, i.e., harm to consumers or a reduction in efficiency (OECD, 2007).
There are unilateral effects and coordinated effects of vertical mergers.
Unilateral effects
In terms of unilateral effects, the Post Chicago School emphasises that vertical mergers can allow a monopolist to extend its monopoly power into other levels of the value chain. The merged entity can foreclose in two ways – input foreclosure and customer foreclosure. During the assessment three questions must be taken into account (Saggers, 2008; more references from journals and book on this) i.e:
- does the merged entity have the ability to foreclose?
- is there an incentive in foreclosing? And
- what anti-competitive effects does foreclosing have?
Input foreclosure (bring in your input foreclosure debates from below up to here)
For input foreclosure to be a significant concern, the vertically integrated firm resulting from the merger must have market power in the upstream market, where it could negatively affect the overall availability of inputs for the downstream market in terms of price or quality. The foreclosure must concern an important input where the input represents a significant cost factor and is a critical component for the downstream players in order for operation to take place. The incentive to foreclose access to inputs solely depends on the degree to which foreclosure would be profitable. Incentives to foreclose involves comparing the merged entity’s trade-off between the possible costs associated with reducing input sales to rivals and not procuring products from upstream rivals and the possible gains from doing so. Lastly, whether the input foreclosure will end up increasing prices which ultimately harms consumers. (references)
[RDN1] Customer foreclosure
Customer foreclosure occurs when post-merger, the downstream market of the integrated firm no longer sources supply from independent upstream firms (OECD, 2007). This depends on whether there are sufficient economic alternatives in the downstream market for the upstream rivals to sell their products. If there is a sufficiently large customer base that is likely to turn to independent suppliers, competition concerns are unlikely to arise (O’Donoghue & Parker, 2007). Upstream rivals’ ability to compete can only be impaired if there are significant economies of scale or scope in the input market. If there is a reduction in sales volume leading to an increase in the average cost or marginal cost of upstream competitors, then, to the extent there is exit because of higher average costs or reduced competitive effectiveness the competitive constraint these firms exert on the upstream division of the integrated firm will be reduced, leading to greater market power upstream and higher input prices (Saggers, 2008). It can reduce competition of rival upstream suppliers if the merger removes an important customer from their customer base, as that buyer now deals only with its own upstream suppliers. Customer foreclosure is deemed to be of concern when after the merger there are few remaining downstream firms to which upstream rivals can sell. The degree of market power is also identified as a driving force for the merged entity to disadvantage rivals and obstruct entry (European Commission Guidelines, 2007).
Coordinated Effects
A merger has the ability to facilitate collusion between firms who are active in the downstream and upstream markets. Vertical integration may facilitate collusion in either the upstream or downstream market (Riordan, 2008). According to the US Non-Horizontal Merger Guidelines 1984, vertical integration by upstream firms into the associated retail market may facilitate collusion in the upstream market by making it easier to monitor prices. (If?) the downstream market is supplied on a contract basis, the vertically integrated entity may maintain a collusive state in the upstream market and can discourage upstream rivals to compete vigorously by threatening to increase competition downstream to discipline these rivals. A vertically integrated firm may enter into exclusive contacts with downstream firms to facilitate collusion in the output market. Secondly, vertical integration has the ability to facilitate collusion through the acquisition of disruptive buyer. According to the Guidelines a disruptive buyer must be the one that is different from the others. The disruptive buyer in the downstream market may facilitate collusion in the upstream market by undercutting each other when selling input to the buyer. The elimination of the buyer from the downstream market may reduce incentives to deviate from a collusive agreement. (add the debates on hub and spoke cartels in vertical relationships).
South African competition authorities have been cautious of vertical mergers which may have the effect of shielding firms from increased competitive forces. [RDN2] ( Mncube, Khumalo and Ngobese, 2012),
Input foreclosure (you already have discussed input foreclosure above – consolidate this under one sub section)
Input foreclosure post-merger occurs when the acquiring firm raises the costs of downstream rivals by restricting their access to an important input that is owned by the merged entity (O’Donoghue & Parker, 2007). Post-merger the integrated firm has an incentive to change the behaviour of its upstream market due to the fact that it will internalise the effect on downstream prices when setting its high price in the market for the input in order to protect its market position upstream. (OECD, 2007). Further, integrated firm in the upstream market may restrict sales of its output to the firms operating with rivals in the downstream market and in the process preferring to operate with its own firms. This conduct could take different forms such as refusal to deal with rivals, putting restrictions on supplies to downstream rivals and degrading the quality of inputs sold to rivals (Riordan and Salop, 1995). This tends to have a competitive disadvantage to the rivals in the downstream market compared to the merged firms that are operating at the downstream market. The merged firms in the downstream market can either grow its market share or gain market power and stronger margins.
The vertically integrated entity’s ability to foreclose depends on whether it has appreciable market power upstream after the merger giving it the ability to influence upstream trading conditions and, therefore, downstream price and supply (Saggers, 2008). The integrated firm will have limited ability to raise the costs of the rivals in the downstream market if there exist strong buyers. Input foreclosure raises competition concerns only if the foreclosed product is an important and irreplaceable input for the downstream market (being either a critical component or an input that has significant cost relative to the price of the downstream product). In many cases, even a dominant upstream supplier will have no incentive to foreclose downstream rivals, especially if they are more efficient downstream producers, if they sell differentiated products, or if the downstream market is larger and more profitable than the upstream market (O’Donoghue & Parker, 2007). Input foreclosure results in a trade off between upstream profit losses against the improved profitability of the downstream market. According to Riordan and Salop (1995) the profitability of the firm operating at the downstream market is enhanced by the degree to which rivals’ costs are raised. Therefore, the integrated firm having the ability and incentive, the vertical merger would definitely raise anticompetitive input foreclosure effects by raising the rival’s costs which will ultimately harm competition and raise prices to consumers.
However, the increase in prices has been identified to be ambiguous in a sense that for a merger to be anti-competitive it shows that it will result to complete foreclosure not partial foreclosure (OECD, 2007). The impact of a vertical merger on downstream market prices has been identified to be difficult to assess even when the integrated firms can commit not to participate in the upstream market. Furthermore, foreclosure is likely to occur in the case of vertical mergers through increased barriers to entry. When downstream rivals are worried about refusals to deal or discriminatory treatment by a vertically integrated input supplier, this might require them to enter at both the upstream and downstream levels simultaneously, which will stipulate increased entry costs and risks. According to the US Non-Horizontal Merger Guidelines (1984), vertical mergers could create competitively barriers to entry. The firms in the upstream market may make entry at the downstream market significantly difficult and less likely to occur.
Vertical restraints
NB*** it is important to also have a section that discusses restrictive vertical agreements. The freezer exclusivity is in effect a restrictive vertical agreement.
1.2 Empirical literature on vertical mergers and vertical restraints
This section reviews the empirical literature on vertical mergers, how other competition authorities have handled the cases of Coca Cola mergers and the competition concerns around exclusion with regards to fridge or cooler space. The section will also look at the impact assessments that were done in South Africa and internationally.
The Common Market for Eastern and Southern Africa (COMESA) Competition Commission in 2015 also assessed and made a decision on the merger that is the subject of this study ( SAB Miller Plc and Coca Cola Sabco Proprietary Limited (Sabco) (2015). The Commission assessed whether the proposed merger would likely have anti-competitive effects in the market such as lessening or preventing competition, or would it have a detrimental effect on public interest. Both parties operate in two or more COMESA Member States such as Ethiopia, Comoros, Kenya, Mauritius, Uganda, Zambia and Zimbabwe. SAB Miller submitted that it was going to establish a subsidiary called Coca-Cola Beverages Africa Limited (“CCBA”) and it would directly or indirectly hold 57% of the shares in the CCBA and exercise its control. The Commission approved the merger without conditions on the basis that it was unlikely to affect the pattern of trade and structure of competition in the Common Market. It was also unlikely to engage in market foreclosure or influence any other conditions of trade in the Common Market to the benefit of its market position and countervailing power. In the analysis it was found that there were several players operating in the relevant product markets over and above the traditional TCCC products. It was also found that any competition concern that would arise would not be as a result of the merger. Therefore, the merger was approved without conditions since it did not substantially prevent or lessen competition. (what are your views on this?)
In Europe the Coca-Cola Company (TCCC) and Cobega (Spain) wanted to acquire Coca-Cola European Partners (CCEP) located in the United Kingdom. TCCC was the brand owner, trademark licensor and producer of soft concentrates, syrups, soft drink syrup and finished beverages. TCCC sells its products to bottlers. Cobega was only active in bottling and distributing beverages. CCEP was a multinational bottling company dedicated to the marketing, production, and distribution of Coca-Cola products. TCCC already controls one of the four bottlers, Coca-Cola Iberian Partners and Vilfilfell. During the assessment it was found that the merger would create the world’s largest Coca-Cola bottler in terms of net revenues. The acquiring firms TCCC and Cobega had exclusive agreements with distributors and marketing. In these agreements distributors and marketing teams were not allowed to offer competing brands. In addition, rivals to Coca-Cola were denied access to outlets due to the effects of Coca-Cola’s financing agreements and technical sales equipment arrangements on beverage coolers and fountain dispensers. During the investigation it was found that beverage coolers and fountain dispensers were offered on a rent to free basis to the retailers and beverage coolers are a superior means to sell ready to drink soft drinks in many outlets. Therefore, if such sales equipment, reserved for Coca-Cola beverages only, is the sole source of carbonated soft drinks in the outlet which is often the case in small shops due to space constraints, access to such outlets would be foreclosed to Coca Cola rivals. Due to space constraints in outlets such as supermarket shelves, access to sales space for rival suppliers would be rendered more difficult and costly. Furthermore, due to the space to sales arrangements, Coca-Cola persuaded its retail customers to reserve a part of their total CSD shelf space to TCCC branded products in proportion to Coca-Cola’s sales share. Due to a large turnover of its three major brands, Coca-Cola Regular, Coca-Cola Light and Fanta Orange, a huge proportion of shelf space was assigned to Coca-Cola’s products. With the shelf space thus reserved, Coca-Cola allocated space which ultimately had a detrimental effect to its rivals. This further deteriorates conditions for access to shops for rival suppliers of carbonated soft drinks, especially those competing with Coca-Cola. The European Commission reached a binding agreement with Coca-Cola where the merger was approved but on condition that Coca-Cola must free up 20% of space in its coolers. The duration of purchase commitments for dispensed beverages is limited to 3 years, with the option to terminate such commitments after the initial two years.
(the case below is not a vertical merger, but a restrictive vertical agreement. Therefore you should have it after you discuss all the mergers)
Another case in Europe regarding freezer involved Langnese-Iglo, a subsidiary of Unilever, and Scholler Lebensmittel. Both companies were the leading firms in Germany in the market for ice creams. Each firm separately had a network of exclusive supply agreements with retailers requiring that retailers buy ice cream only from them and supplying ice cream freezers at no cost. The retailers were also required to use the freezer only for their ice cream and not the ice cream supplied by the rivals. Mars who is a French manufacturer of ice cream bars tried to penetrate the ice cream market and found that the existing firms with their exclusive supply contracts were creating barriers to entry. Therefore, Mars initiated a complaint with the European Commission regarding the exclusivity agreements. The European Commission in its assessment found that that the agreements relating to freezer cabinets installed in outlets have the effect of restricting the ability of retailers to stock and offer for sale in their outlets impulse products from competing companies and it was not economically viable for retailers to allocate space to the installation of an additional cabinet. Further, the European Commission found that new entrants in the market was foreclosed. The European Commission concluded that Unilever was abusing its dominant position in the ice cream market by inducing retailers who did not have a freezer cabinet for the storage for the ice creams or either procured another ice cream supplier. Therefore, the European Commission ultimately decided that Unilever must remove all the exclusivity clauses and that retailers are able to use the Unilever’s cabinet for products produced by competitors. (references).
(below is also not a merger)
The Competition Commission of Mauritius in 2013 launched an investigation into the supply of coolers to retail shops by Phoenix Beverages Limited and Quality Beverages Limited. Phoenix Beverages Limited and Quality Beverages Limited are both stakeholders in the drinks market. Phoenix Beverages Limited operates in the alcoholic and non-alcoholic drinks market whereas Quality Beverages Limited operates in the non-alcoholic market. The investigation discovered that either Phoenix Beverages Limited and Quality Beverages Limited grant coolers to a retailer to stock the drinks produced or distributed by any of the two companies. It was found that the retailer does not stock any other competitor products in the cooler. During the investigation it was found that companies grant coolers with exclusive policy or exclusive agreements and the conduct may have foreclosing anti-competitive effects on the rivals of Phoenix Beverages Limited and Quality Beverages Limited. It was also found that the rivals are unable to provide coolers to retailers either because of costs or space constraints in retail outlets. The main concern that was investigated relates to whether Phoenix Beverages Limited and Quality Beverages Limited by granting coolers with exclusionary agreements may result in an abuse of monopoly power which will result to foreclosure of the rivals who cannot provide coolers for their products. To resolve the competition concerns Phoenix Beverages Limited agreed that the retailer will be free to use 20% of the cooler to stock any product of its choice and that can only happen if the retailer does not have any other chilled beverage capacity in the store. The Commission of Mauritius was of the view that 20% of cooler space is a fair amount which will be given to the rivals and it will foster a level playing field for other competitors. However, the granting of the 20% cooler space came with conditions. The condition was that the 20% cooler space will not apply to rivals who have a market share of 30% or even equal to Phoenix Beverages Limited’s related product market share. The Commission of Mauritius agreed with that condition due to the fact that a rival who has 30% market share or equal to Phoenix Beverages Limited’s related product market share would have leverage in the market and would not be facing any competitive constraint or any budgetary constraints. (references)
(below is also not a merger)
The Competition Commission of Singapore investigated a complaint about Coca Cola Singapore Beverages (CCSB) who incorporated restrictive provisions in supply agreements with the retailers. The Competition Commission of Singapore identified that these supply agreements with retailers may have anti-competitive effects to the competitors. CCSB in order to resolve any competition concerns, voluntarily made changes to its supply agreements. CCSB committed to allow its retailers to use up to 20% cooler space which is provided by CCSB to store other related products, where these retailers have no access to other cooling equipment. Therefore, upon the voluntary action taken by CCSB the Competition Commission of Singapore ceased the investigation and decided that it will keep a close eye on the market practices in the local soft drinks market. (references)
(and now we are back to mergers below. So either organize it such that all vertical merger discussions are together, then all vertical restraints/exclusionary conditions/restrictive vertical agreements).
The South African competition authorities have dealt with a number of other vertical mergers. A seminal case was the Mondi/Kohlr merger, the Tribunal prohibited a proposed merger in 2002 in which Mondi Limited (“Mondi”)[1] wanted to acquire a downstream customer Kohler Cores and Tubes (KC&T)[2]. The Tribunal prohibited the merger because it was likely to prevent or lessen competition in both the upstream and downstream market through foreclosure and it increased the possibility of facilitating collusion. The Tribunal reached its decision to prohibit on the basis that both merging parties had market share which would cause harm to competition should the merger be approved. The Tribunal was also concerned that the merged entity would self-deal as a strategy to weaken downstream rivals and the costs of rivals in the downstream market would be high and KC&T was the only firm with the potential to attract an international supplier for core-board. Further, having the merged entities would have resulted to a block of entry into the upstream market. Furthermore, the Tribunal concluded that the transactions net effect, competition and welfare were negative.
In the case between Bayne Investments (Pty) Ltd (“Bayne”)[3] and Clidet 451 (Pty) Ltd (“Clidet”)[4] the Tribunal approved the transaction with supply conditions on the merging parties. In the merger transaction Woodchem, the target, had a long term supply agreement with PG Bison Limited (“PG Bison”) which is a subsidiary of Steinhoff International, to supply it with formaldehyde resin. The transaction resulted in the vertical integration of Steinhoff International/P G Bison and Woodchem. The Tribunal approved the merger with conditions as it found that input foreclosure would not be profitable for the merged entity in the medium density fibre board (“MDF”) market because the level of imports were relatively high in this market and exercised a constraint on the price of domestic MDF. However, in the event of an increase in resin prices or a refusal to supply by the merged entity to its downstream competitors, the manufacturers of MDF could turn to cheaper imports of MDF. It also found that in the case of particle board it would be profitable for the merged entity to engage in input foreclosure by raising the costs of formaldehyde resin to PG Bison’s rivals. Further, barriers to entry in the downstream market were also relatively high, characterised by high capital costs and long lead times due to the need for environmental impact assessments. Hence the Commission found that a structural remedy, such as requiring a divestiture or separation of the resin production business was not feasible and imposed conditions for a time period of 10 years.
- Impact assessments
Ex-post evaluations are important especially for the competition authorities. These evaluations are important for mainly two reasons, namely they constitute an additional method of justifying the oversight of markets and they bring lessons to the competition authority about which interventions or remedies are effective. The ex post evaluations assist authorities to examine how well intervention or decision of the agency performed. Ex post evaluations are widely done in South Africa and in international jurisdictions. According to the OECD (2016) many ex post evaluations focus on the effect caused on the prices of the goods and services traded on the market affected by the decision, but in some cases they also consider other factors such as quality, variety, innovation, and entry in a particular market. In performing these ex post evaluations competition authorities can select a few tools such as econometric techniques to quantify the magnitude of the changes, qualitative methods and to determine the direction of changes.
Budzinski (2011) provided a comparative analysis of methods for the empirical post evaluation of merger control decisions. Ex post evaluation of past merger decisions represent a tool to improve future decisions by learning from past mistakes. The analysis identified four methods available to be used in the evaluation of merger decisions. The methods identified were structural models and simulations, difference in difference approach, event studies and surveys.
The structural models and simulations are based on an explicit formal model of the nature of competition in the relevant market of the merger and an assessment of the market pre and post-merger. This method gives sound accurate, reliable and valuable insights in the accuracy of merger control decisions. (debate some of the pitfalls. And you need many more references).
Budzinski views the difference in difference approach as the method that encompasses all methods by comparing post-merger performances of market data such as prices, market shares. The method includes an econometric analysis of price and market shares. Difference in difference measures observed data from the relevant product market and it provides an analysis of what actually transpired post-merger in a particular market. Difference in difference must be done on a case by case basis and it requires econometric modelling.
Another method identified is the event studies, whereby it makes use efficient financial markets hypothesis. It measures the price reactions of the merged entities. However, Budzinski found that the event studies method is put into doubt since it gives ambiguous price changes results. Further, it was also found that the method fails to provide a sufficient minimum reliability.
The last method that Budzinski identified is conducting surveys. Surveys are based on follow-up relevant questionnaires and interviews. This method can be applied even when there is no hard data available and is reliable in a sense that it reveals more knowledge to the competition authorities especially information asymmetries.
According to Budzinski all four methods can be designed and executed in inaccurate and insufficient ways. However, literature has shown that using a mixture of the methods is the way to go. Budzinski, concluded that it is beneficial to use alternative methods however, event studies should not form part of those methods due to the fact that they provide unreliable results.
Luca Aguzzoni, Benno Buehler, Luca Di Martile, Ron Kemp and Anton Schwarz have conducted ex-post evaluation of two specific merger decisions in the Austrian and Dutch telecommunications industry undertaken by the DG competition authority. Aguzzoni et al (2017), have applied a standard difference-in-difference approach which is widely used in the literature on ex-post evaluation of mergers to estimate the price effects. The T-Mobile/tele.ring merger in Austria in 2006 was approved with conditions which included that tele.ring must transfer parts of its spectrum and sites to competitors (H3G)., It was the found that after the acquisition, prices in Austria did not increase relative to the considered control countries. (so what was the conclusion? The condition to transfer part of spectrum was the correct condition to have imposed? Discussion is needed, not just summary).
The second merger which was evaluated was the Dutch T-Mobile/Orange merger and it was observed that there was an increase in the mobile tariff prices post-merger in the Netherlands in the analysed period, relative to the control countries. However, it was not confirmed whether the price increase was exclusively caused by the T-Mobile/Orange merger or in part by possible price effects brought about by the KPN/Telfort merger consummated two years earlier in the Netherlands. Furthermore, it was concluded that such price increase could be linked to the structural changes brought by both KPN/Telfort and T-Mobile/Orange mergers together.
The Competition Commission of South Africa has also undertaken an assessment of the impact of the interventions in the nitrogenous fertiliser value chain in 2009 and 2010. In 2003 and 2004 Nutri-Flo and Profert filed complaints with the Commission alleging that Sasol, together with Omnia and Kynoch (Yara), engaged in anticompetitive behaviour. The allegations included an exclusionary abuse of dominance by Sasol and different collusive agreements between Sasol, Omnia and Kynoch (Yara). Ammonia is produced by Sasol who is a dominant supplier and other suppliers of imported ammonia in South Africa are Omnia, Foskor and Kynoch (Yara). Ammonia which is produced by Sasol and imported by Omnia, Foskor and Kynoch (Yara), is used in the production of ammonium nitrate. Sasol, Omnia and AECI have the infrastructure, such as nitric acid plants, to produce ANS solutions. In the downstream market there exists blenders and traders, such as Nutri-Flo and Profert, who sourced input from Sasol to create blended fertilisers. In contravening the Competition Act Sasol and the Commission reached an agreement in which behavioural and structural conditions were imposed on Sasol. In conducting the assessment both qualitative and quantitative methods to assess the extent to which the measures arrived at in the settlement agreement helped to restore competition, in the nitrogenous fertilisers industry were used. The assessment looked at market entry/ expansion/ exit, degree of vertical integration of upstream and downstream market and changes in prices post-intervention period. The assessment found that Omnia has expanded its ammonium nitrate operations, there was also an increase in the supply of ammonia and ammonium nitrate which was caused by the increase in the production and importation of ammonia and ammonium nitrate. Further, it was found that there were more competitive prices to the benefit of farmers. Furthermore, the assessment found that the intervention by the Commission have contributed to customer savings in the fertiliser industry between R1 billion and R10.5 billion between 2010 and June 2015. (References)
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