Conflicts of interest

Principles

A conflict of interest occurs when the judgement of an employee or Associated Person is affected by their external activities or relationships, which may come into direct or indirect conflict with their Halma role or the activities or interests of the Group.

Conflicts of interest should be avoided where possible.  If unavoidable they must be disclosed and managed.

Policy

Halma recognises that employees have a right to take part in legitimate financial, business and other activities outside their Group role.  However, to the extent that these other activities might affect (or potentially be perceived by others to affect) their ability to carry out their Halma role, or affect their judgement, objectivity or loyalty to the Group, they must be disclosed and potentially terminated.

Guidance

Conflicts are most likely to arise in two areas – other business activities and personal relationships.

Other business activities

• You should disclose any business activity you undertake outside the Group to your MD and DCE and obtain their formal approval if you wish to continue with it.
• You should obtain your MD's and DCE’s approval before accepting any position as an officer or director of another business, even as a non-executive director.
• You must not work with, or for, a business that is a competitor, a customer of, or a supplier to, any Halma company.
• You should not have a financial interest in any Halma competitor, customer or supplier (except for normal shareholdings in publicly-listed companies).
• You should not take part in any decision making process involving any Halma company and another business that employs a close family member.

Personal relationships

• Open and friendly relationships between colleagues help create a good working environment. However, individual relationships which become too close can lead to a perception of lack of objectivity or preferential treatment, especially if there is an immediate reporting relationship, and are best avoided.
• You should avoid personal relationships that may conflict with your role or position within Halma – for example if you have a buying role within Halma it would be inappropriate for you to have a close personal relationship with someone on the sales team from a major supplier.

Conflicts should be avoided if at all possible, but if they do occur, the key things are:

• Recognise there is a conflict.
• Disclose it to your MD and DCE.
• Withdraw from any decision-making process affected by the conflict.