What is bribery?

Principles

Bribery is a criminal offence, defined as:

“the offer, promise or gift of a financial or other advantage, with the intention of inducing or rewarding the improper performance of a function or activity.”

It does not matter if:

• the person offering the bribe is the person who will benefit from the improper performance.
• the person receiving the bribe is the person who will carry out the improper performance.

Policy

The Group, from the Halma p.l.c. Board down, has a zero tolerance attitude towards bribery and corrupt practices in all its business dealings.  Such practices are never acceptable and will not be tolerated.  Therefore:

• You should never accept a bribe.
• You should never seek to influence the actions of a third party toward Halma by offering or paying a bribe.
• You should never ask or authorise an Associated Person or any other business partner to offer or pay a bribe on your behalf.

Guidance

At its most basic level, a bribe is an improper financial payment such as a kickback.  However, because a bribe actually involves the offer of an advantage, there are actions beyond a simple payment which might be seen as corrupt.  For example:

• Giving or receiving excessive hospitality and gifts.
• Making inappropriate charitable donations.
• Making or providing political payments and support.
• Making facilitation payments.
• Making payments to intermediaries disproportionate to the service provided.