Insider dealing and price sensitive information

Principles

The share price of a listed company such as Halma p.l.c. is affected by a number of factors, usually associated with its financial and commercial performance. There are times when some employees may have information about that performance which has not yet been announced to the market. This is known as “price sensitive information” – confidential information that may have an influence on the share price - and the misuse or wrongful disclosure of it is a criminal offence.

Policy

Halma and its employees worldwide will comply with all laws and regulations regarding the control of price sensitive information and restrictions on dealing in shares on the basis of such information.

Price sensitive information is extremely confidential and so anyone in possession of it must not take advantage of it by:

Dealing in shares affected by it (insider dealing).
Passing it on to others (improper disclosure).

Guidance

The directors, certain senior executives and employees of Halma (together with persons connected with them) worldwide are restricted in their freedom to deal in Halma p.l.c.’s securities by the requirements of the UK Listing Authorities Code of Dealing (the Model Code) and by other insider dealing and market abuse legislation.

Halma Policy Note A12 (available to Halma employees on the Halma Intranet) sets out the details of these restrictions and the approval process that must be followed by directors and senior employees before they are allowed to deal.

If you believe you know something about Halma which might be price sensitive you should keep it confidential but report it to your DCE and the Halma Company Secretary, since there may be a requirement for a market announcement.

Depending on your role, you might also come into possession of price sensitive information about Halma’s business partners. If so, you should not pass that information on to anyone else and should not use it for your own personal advantage.

Key questions

The following are important questions in relation to price sensitive information:

Do I know something about Halma that might affect the Halma p.l.c. share price?
Do I know something about a business partner that might affect the Halma p.l.c. share price?

If the answer to either of these is yes you should discuss the position with the Halma Company Secretary, Halma Group FD or Halma CEO before taking any related action.

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 DCE and 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

Policy Note A12 (Inside Information and Dealing Restrictions in relation to Halma Shares) available to Halma employees on the Halma Intranet (see Supporting information for details of how to access).