Political payments and involvement
Principles
Halma is a non-political organisation and so supporting local political activity, either by making donations or by other forms of involvement, is difficult to justify. Relationships with politicians and other public officials are also likely to be questioned as to their underlying purpose, especially if the person has influence in areas where the company has activities. However there is a place for proper political lobbying where the intention is to openly convey the Group’s views and concerns to policy makers.
Policy
Halma’s policy is straightforward:
- There is a total prohibition on political payments of any kind by or on behalf of the Group.
- The use of lobbying organisations to represent Halma’s views is permitted provided they are independent and the relationship is properly authorised by your DCE.
- Using politicians or public officials as consultants, or employing them after leaving office, requires careful consideration and authorisation by your DCE before any relationship is agreed.
- You are welcome to participate in your local political process as an individual citizen but you must not involve your employment or company in that participation.
Guidance
A political payment is “a contribution, in cash or in kind, aimed at supporting a political cause.”
“Political cause” can include:
- A political party (or equivalent).
- Party affiliated organisations.
- Party aligned research and lobby groups.
- Individual politicians.
- Individual candidates.
“Contributions” include:
- Loans, pledges, gifts, dues and subscriptions.
- Fees or tickets for conferences, dinners or other fund-raising events.
- Payment for advertising in publications where the main purpose is fund raising rather than commercial.
- Payments to charities, lobbying firms and other organisations that channel funds to political parties or individuals.
- The provision of services at anything other than a full commercial rate and for bona fide business purposes to political parties or individuals.
- The release (paid or unpaid) of employees to undertake political campaigning work, except where this is required of the employee as a consequence of the local political system in the employee’s country and where the release is approved by the employee’s DCE or the senior manager overseeing operations in that country.
Key questions
If you have any doubts about a proposed payment or relationship, ask yourself:
- Is the recipient a political party or cause?
- Is this a relationship with a public or political figure?
- Will this payment or relationship be perceived as a way of seeking undue influence?
If the answer to any of these questions is yes, then you should seek guidance from your manager, MD, DCE or the Halma Company Secretary before making the payment or starting the relationship.
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/2/3 (Political payments and involvement) available to Halma employees on the Halma Intranet (see Supporting information for details of how to access).