Introduction to the Halma Code of Conduct

What is it?

The Code sets out the ethical standards that should govern the activities of Halma and its subsidiaries, its employees and its business partners.

It gives guidance on recognising when and where ethical problems exist and how to avoid them, or what to do if they cannot be avoided.

Why do we need it?

There are three main reasons for having a Code of Conduct:

To raise the profile of ethical issues.

• You need to recognise an ethical problem exists before you can deal with it.
• The Code highlights the main areas where ethical problems occur so that everyone knows what to look out for.

To ensure a consistent response to ethical issues.

• As a business operating in global markets Halma recognises that countries around the world have different local business cultures.
• Because Halma p.l.c. is UK based, all of our operations (and their employees) are governed not only by the bribery and corruption laws of the countries where they operate but also by UK legislation, which applies to the worldwide activities of all UK based or UK controlled companies.
• This Code applies to all of our subsidiaries and employees around the world so that, whatever the local business practice, we adopt consistently high ethical standards.

To provide guidance in specific situations.

• The laws and regulations dealing with ethics and corruption around the world are varied and complex and ignorance is no defence.
• Following this Code should mean that legal (and best practice) compliance is achieved consistently.

Who does it apply to?

• It applies to all Halma operations, their officers and employees.
• Halma’s business partners need to be made aware of the Code and should apply broadly similar ethical standards in their operations.

Where does it apply?

• Halma operates worldwide and this Code applies to all its worldwide operations.

When does it apply?

• It applies at all times.
• Newly acquired companies will adopt the Code from the date they join Halma.

What happens if someone breaches the Code?

• Non-compliance is a very serious matter.  It can lead to civil or criminal sanctions against Halma, its employees and business partners.  It can also lead to:
  • Internal disciplinary action for employees, up to and including dismissal.
  • Immediate termination of any agreement with a business partner.

Getting more information or clarification

• Questions on the application of the Code which cannot be resolved locally should be addressed to the Halma Company Secretary (see Contact details).