The First Conduct Rule (the FCR) is the primary provision in the Competition Ordinance (the Ordinance) that regulates anti-competitive joint action. In the European Union (EU), the relevant provision is Article 101(1) of the Treaty on the Functioning of the European Union (TFEU); and in the United States (US), the relevant provision is Section 1 of the Sherman Act. Many competition law jurisdictions – including Hong Kong, the United Kingdom (UK), and Singapore – have modelled their joint action provision after Article 101(1) TFEU. Article 101(1) TFEU must be read together with Article 101(3), which may be referred to as the ‘efficiency exception’. Joint action that constitutes a prima facie infringement of Article 101(1) but falls within the exception is, overall, not considered illegal under EU competition law. In Hong Kong, the provision which corresponds to Article 101(3) is the exclusion for ‘agreements enhancing overall economic efficiency’ (the Efficiency Exclusion) under Schedule 1 to the Ordinance.