EU COMPETITION LAW AND POLICY IN THE TOURISM SECTOR 37 hotels; (ii) voluntary chains consisting of groups of independent hotels which carry out their marketing, promotion, purchasing etc. under the same hotel brand; and (iii) integrated chains which operate hotels directly through subsidiaries or indirectly by a franchise or management contract72. Regarding the distinction between hotel chains and independent hotels, the first are organised on the basis of a network concept which meets service requirements that go beyond the purely local framework, being much more uniform from one hotel to another and more extensive (e.g. extended opening hours, central reservation system, restaurants, etc.). Further, hotel chains operate under a common hotel name and trademark (making it easier to raise brand awareness) and have a common marketing strategy for all hotels of the chain. They also use their own centralised reservation systems or have access to international reservation systems. On the demand side, large customers such as travel agents, tour operators, corporate customers or others prioritise hotel chains, with which they can enter into framework contracts, setting out negotiated conditions for prices, terms of payment, commissions and discounts. However, the line between hotel chains and independent hotels is becoming increasingly blurred as the latter increasingly organise themselves in voluntary chains. In doing so, they become substitutable to hotel chains and increase the offer available to corporate customers, tour operators and travel agencies73. Furthermore, the hotel operators consider themselves in competition with both independent and chain hotels. Finally, based on the market investigation, the main selection criteria for customers when choosing between hotels within a specific location are factors such as price, comfort level and customers’ ratings. Features such as the affiliation with a chain, the brand and the offering of loyalty programs, by contrast, are not among customers’ main selection criteria74. The hotel accommodation market may further be segmented by comfort/ price level. This segmentation was notably based on the star-rating of each particular hotel, the star rating being indicative of the standard and facilities the customermay expect when selecting a specific hotel75. Previously, theCommission considered narrower sub-segments for hotels having the same star rating, 72 Case M.7902 Marriott/Starwood (2016), para. 17. 73 Ibid. paras. 22-23. 74 Ibid. paras. 28-29 75 Case M.6738 Goldman Sachs / KKR / QMH, para. 14 and following, Case M.1596 Accor / Blackstone / Colony / Vivendi, para. 23 and following.
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