Business relationships

Principles

Halma is involved in many business relationships, from those which are totally arms length with customers and suppliers to those where a business partner is acting on behalf of Halma, such as with agents, contractors, consultants and other intermediaries – those defined as “Associated Persons” in the Glossary. Halma could become involved with corruption due to the actions of these business partners, in particular Associated Persons.

Policy

Halma believes that the basic principles of honesty and openness that it adopts in its dealings should also be adopted by its business partners who should be aware of Halma’s position as set out in this Code of Conduct.

Business partners should never be asked or authorised to do something on Halma’s behalf that is contrary to this Code of Conduct.

All relationships should be governed by a contract, whether it is the straightforward Supplier/Customer relationship covered by Terms of Sale/Purchase, or a more specific contract such as an agency or distributor agreement. Contracts should refer to the Halma Code of Conduct.

Guidance

Before entering into any relationship it makes sense to understand something about the operations involved, particularly for Associated Persons. Therefore it is important that you carry out an appropriate level of investigation or due diligence work to assess their background and identify any concerns. There is a standard procedure for this set out in explanatory note BC/2/5 and appendix BC/2/5/A1 which are available to Halma employees on the Halma Intranet (see Supporting information).

When agreeing any contract, you should pay particular attention to the level of remuneration and the method of payment to ensure that these are in line with normal commercial practice and the level of skill and activity needed.

Key questions

The following are important questions in relation to business relationships:

Will the business partner be seen as an “Associated Person”, i.e. someone acting on behalf of Halma?
Has due diligence or anything you know or may have heard highlighted any business or ethical issues with the business partner?
Is there a formal contract in place defining the relationship?
Does that contract refer to the Halma Code of Conduct?
Does the contract include any unusual terms relating to compensation or payment?

If any answer gives you concern you should discuss the position with your manager, MD, DCE or the Halma Company Secretary.

If you have a concern

Get a better understanding of Group policy by reading the appropriate policy, procedure and explanatory notes (see additional sources of information below).
Raise it with your manager, MD, DCE or the Halma Company Secretary.
If you feel that you cannot talk to them, contact the Expolink Whistleblowing hotline (see Contact details).

Additional sources of information

Explanatory note BC/2/5 (Business Relationships) and appendix BC/2/5/A1 (Due diligence for business relationships) available to Halma employees on the Halma Intranet (see Supporting information for details of how to access).