Whistleblowing

Principles

All Halma employees and business partners are expected to maintain the highest standards of integrity.  If anyone becomes aware of an instance of serious misbehaviour at a Group company then they have a responsibility to help stop it.  Serious misbehaviour includes:

• An action which is a criminal offence or breach of a legal obligation.
• An action that leads to a miscarriage of justice.
• An action which compromises the health and safety of any individual.
• An action which causes damage to the environment.
• The deliberate concealment of information about any of the above.

Policy

Halma believes that the correct approach is to raise concerns with the management of the company where the misbehaviour is occurring so that an appropriate local investigation can be carried out.

However, if you have a strong reason for believing you cannot raise the matter locally, or where you believe the local response is insufficient, you should contact the company’s DCE or the Halma Company Secretary directly, or make use of the Group's whistleblowing hotline.

Halma is committed to ensuring that anyone raising a concern in good faith does not suffer any victimisation or detriment.  It fully endorses and will comply with any local legislation that reinforces that position.  However a concern that is raised maliciously or for no good reason may lead to disciplinary action.

Guidance

What is the whistleblowing hotline?

This is an independent service provided by Expolink Limited, one of the major providers of helpline services in Europe.  Their expertise will ensure the speed and confidentiality of anything you report.

How do I contact the hotline?

Expolink provide local freephone numbers for most countries or have a reverse charge (call collect) number for countries where freephone numbers are not allowed. The hotline is available 24 hours a day, every day of the year (except Christmas Day).

You can also report concerns via the Expolink website or by clicking on the link on the Halma website.  See Contact details.

What happens when I call?

You will talk to one of Expolink’s operators who will listen to and take written notes of your concern.  The call will not be recorded.  Expolink will then securely send a report to the Halma Company Secretary or the Halma Group Finance Director who will ensure that your concern is investigated appropriately.

Do I have to identify myself?

Halma would rather that you did, since this makes investigating the concern and giving feedback easier.  However you may choose to raise a concern anonymously, providing this is allowed by the laws of the country where you work.

Will my call be treated confidentially?

Once Expolink have confirmed that Halma p.l.c. have received their report they will destroy all records of your call.

Halma p.l.c. will maintain the confidentiality of the report as far as is possible but you must be aware that, to carry out a proper investigation, some information may need to be disclosed.

Will I be penalised for raising a concern?

If you raise a concern in good faith you will not be penalised, even if it turns out to be incorrect. However, raising a concern without good reason or maliciously may lead to disciplinary action.

How do I get feedback on my concern?

As part of the hotline conversation the Expolink operator will ask if you want to receive feedback.  If so they will give you a security code and ask that you call back in 4 weeks, quoting the code, at which time they will be able to update you on progress.  The 4 week delay is to allow time for a proper investigation to be carried out.