Here you can find key sustainability-related policies and guidance documents, along with a description and due diligence processes.
Code of conduct
We require our employees to act fairly in their dealings with fellow employees and business partners. ‘Just be a good person’ is the title of our Code of Conduct because it is a crucial part of Halma’s DNA, and summarises our commitment: ‘Play to win, but not at the expense of others. Operate with impeccable ethics, transparency and integrity in all that you do’. Our Code sets out the standards by which we conduct our business. We expect our business partners to act with similarly high ethical standards.
The Code of Conduct aims to ensure that Halma maintains consistently high ethical standards globally, while recognising that our businesses operate in markets and countries with cultural differences and practices. It has been translated into 10 languages, and is issued to all Halma employees and published on our website.
Halma has a zero-tolerance policy on bribery and corruption which extends to all business dealings and transactions in which the Group is involved. Please see the Code of Conduct for an overview of Halma’s position in relation to bribery and corruption and the Halma Annual Report and Accounts for details as to Halma’s Anti-Bribery and Corruption Policy.
Halma and its companies are committed to not engaging in any unlawful transactions, including those that facilitate tax evasion. Halma and it companies have policies, procedures and controls in place to ensure accurate, complete and transparent reporting and compliance with applicable tax evasion laws and regulations. Please see the Code of Conduct for an overview of Halma’s position in relation to tax evasion.
Halma and its companies are committed to not engaging in any unlawful transactions, including those that utilise property derived from illegal conduct or that support crime or terrorism. Halma and it companies have policies, procedures and controls in place to ensure accurate, complete and transparent reporting and compliance with applicable money laundering and counter terrorism laws and regulations. Please see the Code of Conduct for an overview of Halma’s position in relation to money laundering and terrorism financing.
Halma is committed to building a diverse and inclusive culture throughout the Group. Diversity, Equity and Inclusion is one of our Key Sustainability Objectives as we believe it benefits the global economy and creates a fairer future for everyone, every day.
The benefits of diversity across all levels of the organisation are clear and the unique culture that each of our businesses bring – through innate differences in our people – is the foundation for our success. Creating inclusive environments, where everyone has equal access, opportunity and treatment and can bring their full self to work, is fundamental to accelerating our growth and achieving our purpose.
The Board has agreed the following commitments, which are in line with the FTSE Women Leaders Review recommendations and go beyond the targets recommended by the Parker Review:
- to maintain gender balance at Board and Executive Board level by ensuring that representation of both men and women is at or above a minimum 40% threshold and, by 31 December 2025, ensure a minimum representation of men or women one-level below the Executive Board is at or above the 40% threshold;
- to have at least one woman in the Chair or Senior Independent Director role and/or one woman in the CEO or CFO role;
- to maintain at least two ethnically diverse Directors on the Board;
- to have at least 20% of senior management positions (defined as the Executive Board and their direct reports, excluding administration staff) occupied by ethnically diverse executives by December 2027; and
- as a signatory to Change The Race Ratio, we commit to increase racial and ethnic diversity at senior leadership level, to be transparent on targets and actions, and to create an inclusive culture in which talent from all backgrounds can thrive.
Approved by the Board of Halma plc on 6 June 2024
Halma and its companies believe in fair competition and are committed to complying fully with all applicable competition laws. Please see the Code of Conduct for further information in relation to Halma’s expectations in relation to competing fairly and the Halma Annual Report and Accounts.
One particular area of concern for our customers and other stakeholders is whether certain minerals (3TG) that may originate in conflict-affected areas are included in our products. Legislation including The Dodd-Frank Act and the EU Conflict Minerals Regulations requires companies to act. In order to assist our customers who are subject to these regulations, we have a Conflict Minerals Policy which gives guidance to all companies on how to determine whether any of the four minerals, or their derivatives, classified as ‘conflict minerals’ are contained in any product.
This policy is available to all employees of Halma and our companies, and is not published externally.
At Halma we are focused on fulfilling the Group’s purpose and always promote the best interests of the Group and our stakeholders. To ensure that all business decisions are made in the best interest of our business, we expect our people to avoid a conflict with all personal interests that could affect our ability to make fair, objective business decisions. Please see the Code of Conduct for further information in relation to Halma’s expectations in relation to managing conflicts of interest.
Halma and its companies are committed to collecting personal information only when necessary and using it both in an ethical manner and in compliance with all applicable data privacy laws. Please see the Code of Conduct for further information in relation to Halma’s expectations in relation to data ethics and the Halma Annual Report and Accounts for details as to Halma’s Data Protection Policy.
Our Diversity and Inclusion Policy sets out our commitment to building inclusive and diverse businesses, and is available at www.halma.com. More information about our commitment and progress on diversity, equity and inclusion can be found in the 'Support our People' section on pages 84 to 87 of Halma's Annual Report and Accounts.
Halma’s Environmental Policy has been set by the Board, and our Sector Chief Executive, Environmental & Analysis, & Chief Sustainability Officer, has principal responsibility for coordinating and monitoring. This internal-facing policy includes our Carbon Policy and our Environmental Commitment statement, available at www.halma.com, and sets out our guiding principles and commitments for both internal and external audiences.
We encourage our companies and their suppliers to improve energy productivity, reduce water consumption, waste and emissions and, in terms of materials, to reduce or make more efficient use of them. Focusing on our sustainability pillar of Protecting our environment will help us limit our key environmental impacts including energy consumption, GHG emissions and hazardous and other waste production.
More information on our programmes to reduce our environmental impact and data is available in the Sustainability section of our Annual Report and Accounts, and our assessment of and response to climate-related risks and opportunities as well as our energy and emissions performance can be found in our TCFD Statement in our Annual Report and Accounts, and in further detail in our ESG Data Supplement.
We are committed to promoting equality of opportunity for all employees and job applicants. We aim to create a working environment in which all individuals are able to make best use of their skills, free from discrimination or harassment, and in which all decisions are based on merit. It is a Group policy to not discriminate against staff or candidates on the basis of age, disability, gender, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, or sexual orientation.
While we encourage an open culture where any issues can be raised and handled locally at business level, we recognise that there will be times when it is not appropriate, or a person will not be comfortable raising a concern through line management. NavexGlobal, an independent third-party, provides our confidential reporting service to enable any concerned parties, including employees and suppliers, to raise any concerns they may have in confidence, via telephone or web-reporting. Where permitted by law, employees may report anonymously if they wish.
We recognise that we are better equipped to achieve our purpose of growing a safer, cleaner, healthier future for everyone, every day if we build inclusive businesses that reflect the communities in which we live and work. Read more about our Gender Pay Gap.
The health and safety of Halma’s people and the people we work with are our first priority. Halma and its companies are committed to providing a safe and secure working environment and upholding the highest health and safety standards. Please see the Code of Conduct for further information in relation to Halma’s expectations in relation to health and safety and the Halma Annual Report and Accounts for details as to Halma’s Health and Safety Policy.
Halma’s Human Rights and Labour Conditions Policy reflects the core requirements of the Universal Declaration of Human Rights and the Group observes the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work, including the conventions relating to forced labour, child labour, non-discrimination, freedom of association and right to collective bargaining. The Group Chief Executive has overall responsibility for ensuring that human rights considerations are integral to the way in which existing operations and new opportunities are developed and managed. Compliance with, and respect for, these fundamental principles are integrated throughout our organisation. Managers and supervisors must provide leadership that promotes human rights as an equal priority to other business issues. All employees are responsible for ensuring that their own actions do not impair the human rights of others, and are encouraged to bring forward, in confidence, any concerns they may have about human rights.
Halma is committed to conducting its business ethically and in line with all relevant legislation including human rights laws. Halma has published Modern Slavery Act Statements since September 2016, which detail the progressive steps taken annually to tackle modern slavery and human trafficking.
All companies have been provided with a detailed guidance note to raise awareness of the Modern Slavery Act and the issue of modern slavery in business and supply chains. Each company is required to consider the potential issue of modern slavery and human trafficking within their business and supply chain and may take varying approaches, such as supplier due diligence, questionnaires and the use of terms and conditions, according to their specific circumstances.
In addition, online compliance training on the Modern Slavery Act has been rolled out to senior management, all company board members and other relevant employees across the Group. Over 650 employees have completed this training during the year ended 31 March 2024. This is an important tool to assist our business management in raising awareness of the issues and understanding their responsibilities in their operations.
Further information on steps taken during the year in relation to Modern Slavery can be found in our Modern Slavery Act Statement.
As a global business, Halma believes in fully complying with international trade laws (including economic sanctions, import and export laws and controls and anti-boycott laws) in all jurisdictions where it operates. Halma and its companies are committed to implementing appropriate controls, policies and procedures to help support the lawful export of all goods, services, information and technologies. Please see the Code of Conduct for an overview of Halma’s expectations in relation to trade compliance.
The Transparency in Coverage Final Rules require certain group health plans to disclose on a public website information regarding in-network provider rates and historical out-of-network allowed amounts and billed charges for covered items and services in two separate machine-readable files (MRFs). The MRFs for the benefit package options under the Halma Holdings, Inc. Group Health and Flexible Benefit Plan is linked here: https://transparency-in-coverage.uhc.com/
Halma has a Group-wide Whistleblowing Policy in place. While we encourage an open culture where any issues can be raised and handled locally at business level, we recognise that there will be times when it is not appropriate, or a person will not be comfortable raising a concern through line management. NavexGlobal, an independent third-party, provides our confidential reporting service to enable any concerned parties, including employees and suppliers, to raise any concerns they may have in confidence, via telephone or web-reporting. Where permitted by law, employees may report anonymously if they wish. Halma is committed to ensuring that anyone raising a concern in good faith is not subject to any victimisation or detrimental treatment. It will also protect those against whom claims are made, where the person making the claim does so maliciously, and knowing it to be untrue. Details about the confidential reporting service are available in our Code of Conduct (which is available on our website), and Sharepoint sites, and are prominently displayed on posters within all of our Group and operating company locations.
All reports are appropriately investigated and concluded. The Audit Committee receives details of any reports relating to financial misconduct and the Board receives an overview of reports relating to people and culture.
