73Second, it should be borne in mind that the Commission found the applicant liable only with respect to the technical meetings in which an individual employed by H&R ChemPharm had participated, according to its evaluation of the documents in its possession (see paragraphs 45 to 52 above). The presence of an employee or other representatives at anti-competitive meetings is a factual element that enables the Commission to find an undertaking liable for an infringement of Article 81 EC. According to the case-law, the Commission’s power to impose a sanction on an undertaking where it has committed an infringement presumes only the unlawful action of a person who is generally authorised to act on behalf of the undertaking (Joined Cases T-236/01, T-239/01, T-244/01 to T-246/01, T-251/01 and T-252/01Tokai Carbon and Others v Commission [2004] ECR II-1181, paragraph 277; Case T-141/08E.ON Energie v Commission [2010] ECR II-5761, paragraph 258; see also, to that effect, Joined Cases 100/80 to 103/80 Musique Diffusion française and Others v Commission [1983] 1825, paragraph 97).