Halma Code of Conduct - Riester

Integrity in BusinessThe Halma Code of Conduct

Halma Code of Conduct – September 2011This Code of Conduct summarises our ethical commitment. It offers guidelines and policies that definehow we run our business. It will help deliver consistently high standards of conduct throughout theGroup, reinforcing our reputation around the world. We expect our business partners, as well as ouremployees, to act with similarly high ethical standards.The Code should help our employees and business partners identify and avoid situations that mightviolate legislation and best practice. Understanding the relevant laws around the world is not alwayseasy but this Code, encompassing Halma‟s policies on Bribery and Corruption, Conflicts of Interest,Insider Dealing and Whistleblowing, covers the major areas. It cannot deal with every circumstance soif it does not give you enough guidance about how to deal with a particular situation, consult yourmanager, MD, Divisional Chief Executive or the Halma Company Secretary.Compliance with the Code is not only of concern to Halma, the business, but also to each employee.For example, bribery is illegal and will expose the business to prosecution, fines and loss of reputation.However, it could also expose employees personally to penalties including fines and, in extreme cases,even imprisonment.If you are aware of any employee or operation involved in illegal acts or acting contrary to the Code ofConduct, you must immediately report it to your manager, MD, Divisional Chief Executive or the HalmaCompany Secretary. If you have any concern over how your complaint might be handled by your linemanager, please use the Whistleblowing policy (see page 17).Compliance with the Code is mandatory across the Group worldwide. We all share responsibility forensuring that individually and collectively we are complying with this Code. I know that I can count onyour support and will always do what I can to support you in doing the right thing.RegardsAndrew WilliamsChief Executive

Halma Code of Conduct – September 2011CONTENTSPageIntroduction to the Halma Code of Conduct 1Supporting Information Glossary 3 Additional sources of information 3Bribery and corruption What is bribery? 4 Entertainment, gifts and promotional spend 5 Charitable giving 7 Political payments and involvement 8 Facilitation payments 10 Business relationships 12 Accuracy of recording and reporting 13Insider dealing and price sensitive information 14Conflicts of interest 15Whistleblowing Principles, policy and guidance 17 Contact details 20

Halma Code of Conduct – September 2011INTRODUCTION TO THEHALMA CODE OF CONDUCT( co ntinued)Who does it apply to?It applies to all Halma operations, their officers andemployees.Halma‟s business partners need to be made aware ofthe Code and should apply broadly similar ethicalstandards in their operations.Where does it apply?Halma operates worldwide and this Code applies to allits worldwide operations.When does it apply?It applies at all times.Newly acquired companies will adopt the Code from thedate they join Halma.What happens if someone breaches the Code?Non-compliance is a very serious matter. It can lead tocivil or criminal sanctions against Halma, its employeesand business partners. It can also lead to:o Internal disciplinary action for employees, up toand including dismissal.o Immediate termination of any agreement with abusiness partner.Getting more information or clarificationQuestions on the application of the Code which cannotbe resolved locally should be addressed to the HalmaCompany Secretary (see page 20 for contact details).Page 2

Halma Code of Conduct – September 2011SUPPORTING INFORMATIONGlossaryThroughout this Code of Conduct you will find certain termsused which have the following meanings:Halma or GroupHalma p.l.c. and any or all of its subsidiaries.DCEDivisional Chief Executive.Associated PersonSomeone (an individual or a business) who performsservices for or on behalf of Halma. This can include:Officers and employees.Parent or subsidiary companies.Joint ventures.Agents, contractors and consultants depending on theircontractual terms.Public OfficialA person who either:Holds a legislative, administrative or judicial position ofany kind, appointed or elected, of a country or territory.Exercises a public function for or on behalf of anycountry or territory, or for or on behalf of any publicagency or public enterprise of that country.Is an official or agent of a public internationalorganisation, such as the UN.Additional sources of informationEach section of the Code may have a reference to additionalsources of information, usually Halma policy or procedurenotes, which expand on the Code. These additional notesare available from the Halma Intranet as follows:Using the search function, search for the note reference(for example „A12‟ or „BC/2/4‟).Clicking on „Documents‟, then „Policy and ProcedureNotes‟, will take you to the full Procedure Note indexwhich you can scroll through to find the note you need.If you do not have Intranet access, copies of the documentscan be obtained from your manager or MD.Page 3

Halma Code of Conduct – September 2011WHAT IS BRIBERY?PrinciplesBribery 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 improperperformance of a function or activity.”It does not matter if:the person offering the bribe is the person who willbenefit from the improper performance.the person receiving the bribe is the person who willcarry out the improper performance.PolicyThe Group, from the Halma p.l.c. Board down, has a zerotolerance attitude towards bribery and corrupt practices in allits business dealings. Such practices are never acceptableand will not be tolerated. Therefore:You should never accept a bribe.You should never seek to influence the actions of a thirdparty toward Halma by offering or paying a bribe.You should never ask or authorise an AssociatedPerson or any other business partner to offer or pay abribe on your behalf.GuidanceAt its most basic level, a bribe is an improper financialpayment such as a kickback. However, because a bribeactually involves the offer of an advantage, there are actionsbeyond a simple payment which might be seen as corrupt.For example: Giving or receiving excessive hospitality and gifts(see page 5). Making inappropriate charitable donations (see page 7). Making or providing political payments and support(see page 8). Making facilitation payments (see page 10). Making payments to intermediaries disproportionate tothe service provided (see page 12).Key QuestionsYou should always consider thereasons underlying any action andif you have any doubts about itslegality or purpose, ask yourselfthese two questions:Would I be happy to justify myposition if the details of thisappeared in a nationalnewspaper?Would I be happy if I found outthat my main businesscompetitor was doing this?If the answer to either of thesequestions is no, then there areclearly concerns and you shouldseek guidance from your manager,MD, DCE or the Halma CompanySecretary before proceeding.If you have a concernGet a better understanding ofGroup policy by reading theappropriate policy, procedureand explanatory notes (seeadditional sources ofinformation below).Raise it with your manager,MD, DCE or the HalmaCompany Secretary.If you feel that you cannot talkto them, contact the ExpolinkWhistleblowing hotline (seepage 17).Additional sources ofinformationHalma Procedure Notes BC/1/1(Bribery and corruption policystatement) and BC/1/2 (Briberyand corruption control procedure)available on the Halma Intranet(see page 3 for details of how toaccess).Page 4

Halma Code of Conduct – September 2011ENTERTAINMENT, GIFTS ANDPROMOTIONAL SPENDPrinciplesGifts and entertainment are useful for building andmaintaining relationships between business partners.However, they may be seen as creating a conflict of interestby placing the recipient under an obligation to the giver,making them more likely to favour the giver in businessdecisions. This is particularly the case if spend levels areexcessive or unreasonable compared to the status of therecipient or to local business customs.PolicyYou should never directly ask for a gift or hospitality.Reasonable gifts, hospitality and other promotionalexpenditure may be both provided or accepted so longas they:o Have a clear business purpose.o Are appropriate to the seniority of the recipient andare in line with local business customs.o Are not intended to influence the recipient‟s actionstoward the giver.o Do not contravene local laws or the recipient‟s ownCode of Conduct.o Are visible – properly authorised, recorded andaccounted for.GuidanceThere is nothing wrong or inappropriate about giving orreceiving small gifts or reasonable entertainment andhospitality - the difficulties come in judging what isappropriate and what is not. Key to this are purpose, valueand visibility.PurposeAny gift or hospitality should be seen as astraightforward way of building or maintaining therelationship. If there is any chance it will be perceivedas a means of influencing or rewarding the recipientthen it should not be offered or accepted. Therefore it isbetter to avoid giving or receiving gifts or hospitality atkey points during negotiations.There should be a business purpose to hospitality.Employees from both the giver‟s and the recipient‟sorganisations should be at any event, otherwise there isno scope for business discussion.Key questionsIf you have any doubts about thelegality, purpose, or value of a giftor hospitality, ask yourself thesefour questions:Will it be seen as beingintended to influence therecipient‟s business decision?Is it prohibited by local laws orthe recipient‟s Code ofConduct?Does the value or naturemean I feel uncomfortableabout accepting it?Does its value or nature meanthat I need my MD‟s approvalbefore I offer (or accept) it?If the answer to any of thesequestions is yes, seek guidancefrom your manager, MD, DCE orthe Halma Company Secretarybefore proceeding.If you have a concernGet a better understanding ofGroup policy by reading theappropriate policy, procedureand explanatory notes (seeadditional sources ofinformation below).Raise it with your manager,MD, DCE or the HalmaCompany Secretary.If you feel that you cannot talkto them, contact the ExpolinkWhistleblowing hotline (seepage 17).Additional sources ofinformationExplanatory note BC/2/1(Entertainment, gifts andpromotional spend) available onthe Halma Intranet (see page 3 fordetails of how to access).Page 5

Halma Code of Conduct – September 2011CHARITABLE GIVINGPrinciplesSupporting charities is a good and positive thing to do but itis not really part of Halma‟s corporate role. Rather thanmaking corporate decisions about the merits of worthwhilecauses, Halma would rather ensure that its stakeholdersreceive the best possible rewards so allowing them toindividually support their personal interests.Charitable payments can pose problems if they are seen asa way of channelling funds to reward a third party bysupporting their favoured cause.PolicyThe Group has no large-scale charitable giving programmebut there is no prohibition on low-level local giving by Halmacompanies, provided that donations:Are small compared to the size of the business, normallyless than GBP 250 (or local equivalent).Are to a registered charity, or a well-recognised andindependent equivalent, whose purpose benefits a widesection of the population rather than a few individuals.Are not made in expectation of reward.Do not contravene local legislation.Halma companies are allowed to fund student scholarshipsas a positive way of interacting with their local communityprovided that the means of choosing the beneficiary isdemonstrably fair and open.There is no intention to prevent employees continuing toorganise their own fund-raising activities and charitablegiving programmes. These should continue to be agreedwith local management.GuidanceIt is important that there is proper visibility and approval ofthis type of expense, therefore:Charitable donations within the above levels need yourMD to sign off the payment.Donations that do not meet these criteria must haveDCE signoff and be recorded in a register which will bereviewed by Group staff.Donations must be properly recorded in the accountingrecords and correctly shown in financial reports.Key questionsIf you have any doubts aboutwhether a charitable donation isappropriate, ask yourself thesequestions:Am I satisfied that this is abona fide charity?Is the charity independent ofany business relationship?Is the donation allowed bylocal legislation?If the answer to any of thesequestions is no, then you shouldnot offer the donation without firstseeking guidance from yourmanager, MD, DCE or the HalmaCompany Secretary.If you have a concernGet a better understanding ofGroup policy by reading theappropriate policy, procedureand explanatory notes (seeadditional sources ofinformation below).Raise it with your manager,MD, DCE or the HalmaCompany Secretary.If you feel that you cannot talkto them, contact the ExpolinkWhistleblowing hotline (seepage 17).Additional sources ofinformationExplanatory note BC/2/2(Charitable giving) available on theHalma Intranet (see page 3 fordetails of how to access).Page 7

Halma Code of Conduct – September 2011POLITICAL PAYMENTS ANDINVOLVEMENTPrinciplesHalma is a non-political organisation and so supporting localpolitical activity, either by making donations or by otherforms of involvement, is difficult to justify. Relationships withpoliticians and other public officials are also likely to bequestioned as to their underlying purpose, especially if theperson has influence in areas where the company hasactivities. However there is a place for proper politicallobbying where the intention is to openly convey the Group‟sviews and concerns to policy makers.PolicyHalma‟s policy is straightforward:There is a total prohibition on political payments of anykind by or on behalf of the Group.The use of lobbying organisations to represent Halma‟sviews is permitted provided they are independent andthe relationship is properly authorised by your DCE.Using politicians or public officials as consultants, oremploying them after leaving office, requires carefulconsideration and authorisation by your DCE before anyrelationship is agreed.You are welcome to participate in your local politicalprocess as an individual citizen but you must not involveyour employment or company in that participation.GuidanceA 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 fundraisingevents.Key questionsIf you have any doubts about aproposed payment or relationship,ask yourself:Is the recipient a political partyor cause?Is this a relationship with apublic or political figure?Will this payment orrelationship be perceived as away of seeking undueinfluence?If the answer to any of thesequestions is yes, then you shouldseek guidance from your manager,MD, DCE or the Halma CompanySecretary before making thepayment or starting therelationship.If you have a concernGet a better understanding ofGroup policy by reading theappropriate policy, procedureand explanatory notes (seeadditional sources ofinformation below).Raise it with your manager,MD, DCE or the HalmaCompany Secretary.If you feel that you cannot talkto them, contact the ExpolinkWhistleblowing hotline (seepage 17).Additional sources ofinformationExplanatory note BC/2/3 (Politicalpayments and involvement)available on the Halma Intranet(see page 3 for details of how toaccess).Page 8

Halma Code of Conduct – September 2011POLITICAL PAYMENTS ANDINVOLVEMENT ( continued)Guidance (continued)Payment for advertising in publications where the mainpurpose is fund raising rather than commercial.Payments to charities, lobbying firms and otherorganisations that channel funds to political parties orindividuals.The provision of services at anything other than a fullcommercial rate and for bona fide business purposes topolitical parties or individuals.The release (paid or unpaid) of employees to undertakepolitical campaigning work, except where this is requiredof the employee as a consequence of the local politicalsystem in the employee‟s country and where the releaseis approved by the employee‟s DCE or the seniormanager overseeing operations in that country.Page 9

Halma Code of Conduct – September 2011FACILITATION PAYMENTS( co ntinued)Guidance (continued)Use techniques such as:Carrying a local language card on business trips statingthe company‟s policy and pointing out that making suchpayments is against UK law.Taking detailed notes of conversations where paymentsare demanded.Asking for written evidence that the payment is officiallyrequired.Requesting an official receipt for any payment, includingdetails of the recipient‟s name and identity number.Demanding confirmation from the supervisor/manager ofthe person making the demand.Asking to contact your company to discuss the issue andthe line to be taken.Asking to contact the local embassy/consulate todiscuss and report the issue.If, despite using these techniques, you are still met by thedemand and you feel there is a threat of physical violence,loss of liberty, or of some other adverse effect on yourpersonal well-being, you should make the payment. Youshould then immediately report it to your manager and MD,who will then report it to your DCE and to Group.Any facilitation payments made, even under duress, shouldbe properly recorded and analysed in your company‟sfinancial records and reports.You should also report any demands that were successfullyresisted so that the incidence of these demands can bemonitored and successful defence strategies identified.Page 11

Halma Code of Conduct – September 2011BUSINESS RELATIONSHIPSPrinciplesHalma is involved in many business relationships, fromthose which are totally arms length with customers andsuppliers to those where a business partner is acting onbehalf of Halma, such as with agents, contractors,consultants and other intermediaries – those defined as“Associated Persons” in the Glossary. Halma could becomeinvolved with corruption due to the actions of these businesspartners, in particular Associated Persons.PolicyHalma believes that the basic principles of honesty andopenness that it adopts in its dealings should also beadopted by its business partners who should be aware ofHalma‟s position as set out in this Code of Conduct.Business partners should never be asked or authorised todo something on Halma‟s behalf that is contrary to this Codeof Conduct.All relationships should be governed by a contract, whetherit is the straightforward Supplier/Customer relationshipcovered by Terms of Sale/Purchase, or a more specificcontract such as an agency or distributor agreement.Contracts should refer to the Halma Code of Conduct.GuidanceBefore entering into any relationship it makes sense tounderstand something about the operations involved,particularly with Associated Persons. Therefore it isimportant that you carry out an appropriate level ofinvestigation or due diligence work to assess theirbackground and identify any concerns. There is a standardprocedure for this set out in explanatory note BC/2/5 andappendix BC/2/5/A1 (see Additional Sources of Information).When agreeing any contract, you should pay particularattention to the level of remuneration and the method ofpayment to ensure that these are in line with normalcommercial practice and the level of skill and activityneeded.Key questionsThe following are importantquestions in relation to businessrelationships:Will the business partner beseen as an “AssociatedPerson”, i.e. someone actingon behalf of Halma?Has due diligence or anythingyou know or may have heardhighlighted any business orethical issues with the businesspartner?Is there a formal contract inplace defining the relationship?Does that contract refer to theHalma Code of Conduct?Does the contract include anyunusual terms relating tocompensation or payment?If any answer gives you concernyou should discuss the position withyour manager, MD, DCE or theHalma Company Secretary.If you have a concernGet a better understanding ofGroup policy by reading theappropriate policy, procedureand explanatory notes (seeadditional sources ofinformation below).Raise it with your manager,MD, DCE or the HalmaCompany Secretary.If you feel that you cannot talkto them, contact the ExpolinkWhistleblowing hotline (seepage 17).Additional sources ofinformationExplanatory note BC/2/5 (BusinessRelationships) and appendixBC/2/5/A1 (Due diligence forbusiness relationships) available onthe Halma Intranet (see page 3 fordetails of how to access).Page 12

Halma Code of Conduct – September 2011ACCURACY OF RECORDINGAND REPORTINGPrinciplesThe financial and other records of the Group form the basisof both statutory reporting and also the periodic reports usedby managers to understand business activity and plan forthe future. Errors in recording transactions, for whateverreason, mean that management decisions can be based onan incorrect view of the situation with potentially seriousbusiness consequences. Deliberate falsification, often usedto try to conceal a corrupt action, may also be fraudulent inits own right and could lead to civil or criminal liabilities, bothfor the perpetrator and for Halma itself.PolicyHalma will comply with all laws, regulations and rulesrelating to record keeping and reporting that apply in eachcountry where it operates. It has policies, procedures andcontrols, supported by formal reviews and internal audit, toensure that compliance is achieved.GuidanceThere is never any justification for mis-recording or misreporting.Trying to hide wrong-doing in anything but thevery short term is unlikely to be successful and, while theconsequences of owning up may be considerable, theconsequences arising from disclosure of a cover-up areinevitably far worse.Halma has in place a wide range of policies, procedures,reporting and control processes aimed at ensuring thatrecording and reporting is accurate and complete. Theserun from basic items such as standardised documentation,segregation of duties, authority and approval processesthrough to periodic financial reviews and Internal Audit.In addition each MD and FD is required to certify each yearthat they have maintained proper controls over theirbusinesses.Key questionsThe following are importantquestions in relation to accuraterecording and reporting:Am I aware of any misanalysisor mis-recording inmy company‟s records?Am I aware of any breakdownin the approval or other controlprocesses?If the answer to any of these is yesyou should discuss the positionwith your manager, MD, DCE orthe Halma Company Secretary.If you have a concernGet a better understanding ofGroup policy by reading theappropriate policy, procedureand explanatory notes (seeadditional sources ofinformation below).Raise it with your manager,MD, DCE or the HalmaCompany Secretary.If you feel that you cannot talkto them, contact the ExpolinkWhistleblowing hotline (seepage 17).Additional sources ofinformationVarious Halma Policy andProcedure notes available on theHalma Intranet (see page 3 fordetails of how to access).Page 13

Halma Code of Conduct – September 2011INSIDER DEALING AND PRICESENSITIVE INFORMATIONPrinciplesThe share price of a listed company such as Halma p.l.c. isaffected by a number of factors, usually associated with itsfinancial and commercial performance. There are timeswhen some employees may have information about thatperformance which has not yet been announced to themarket. This is known as “price sensitive information” –confidential information that may have an influence on theshare price - and the misuse or wrongful disclosure of it is acriminal offence.PolicyHalma and its employees worldwide will comply with all lawsand regulations regarding the control of price sensitiveinformation and restrictions on dealing in shares on the basisof such information.Price sensitive information is extremely confidential and soanyone in possession of it must not take advantage of it by:Key questionsThe following are importantquestions in relation to pricesensitive information:Do I know something aboutHalma that might affect theHalma p.l.c. share price?Do I know something about abusiness partner that mightaffect the Halma p.l.c. sharevalue?If the answer to either of these isyes you should discuss the positionwith the Halma CompanySecretary, Halma Group FD orHalma CEO before taking anyrelated action.If you have a concernDealing in shares affected by it (insider dealing).Passing it on to others (improper disclosure).GuidanceThe directors, certain senior executives and employees ofHalma (together with persons connected with them)worldwide are restricted in their freedom to deal in Halmap.l.c.‟s securities by the requirements of the UK ListingAuthorities Code of Dealing (the Model Code) and by otherinsider dealing and market abuse legislation.Get a better understanding ofGroup policy by reading theappropriate policy, procedureand explanatory notes (seeadditional sources ofinformation below).Raise it with your DCE and theHalma Company Secretary.If you feel that you cannot talkto them, contact the ExpolinkWhistleblowing hotline (seepage 17).Halma Policy Note A12 sets out the details of theserestrictions and the approval process that must be followedby directors and senior employees before they are allowedto deal.If you believe you know something about Halma which mightbe price sensitive you should keep it confidential but report itto your DCE and the Halma Company Secretary, since theremay be a requirement for a market announcement.Additional sources ofinformationPolicy Note A12 (Inside Informationand Dealing Restrictions in relationto Halma Shares) available on theHalma Intranet (see page 3 fordetails of how to access).Depending on your role, you might also come intopossession of price sensitive information about Halma‟sbusiness partners. If so, you should not pass thatinformation on to anyone else and should not use it for yourown personal advantage.Page 14

Halma Code of Conduct – September 2011CONFLICTS OF INTERESTPrinciplesA conflict of interest occurs when the judgement of anemployee or Associated Person is affected by their externalactivities or relationships, which may come into direct orindirect conflict with their Halma role or the activities orinterests of the Group.Conflicts of interest should be avoided where possible. Ifunavoidable they must be disclosed and managed.PolicyHalma recognises that employees have a right to take part inlegitimate financial, business and other activities outsidetheir Group role. However, to the extent that these otheractivities might affect their ability to carry out their Halmarole, or affect (or potentially be perceived by others to affect)their judgement, objectivity or loyalty to the Group, they mustbe disclosed and potentially terminated.GuidanceConflicts are most likely to arise in two areas – otherbusiness activities and personal relationships.Other business activitiesYou should disclose any business activity you undertakeoutside the Group to your MD and DCE and obtain theirformal approval if you wish to continue with it.You should obtain your MD‟s and DCE‟s approval beforeaccepting any position as an officer or director ofanother business, even as a non-executive director.You must not work with, or for, a business that is acompetitor, a customer of, or a supplier to, any Halmacompany.You should not have a financial interest in any Halmacompetitor, customer or supplier (except for normalshareholdings in publicly-listed companies).You should not take part in any decision making processinvolving any Halma company and another business thatemploys a close family member.Key questionsThe following are importantquestions in relation to conflicts ofinterest:Do I have to choose betweenHalma and something/someone else when makingthis decision?Would disclosing therelationship to my workcolleagues cause meembarrassment?Is this personal relationshipinfluencing my businessdecisions?Am I recruiting, managing, orappraising a friend or familymember?If the answer to any of these is yesyou should discuss the positionwith your manager, MD, DCE orthe Halma Company Secretary.If you have a concernRaise it with your manager,MD, DCE or the HalmaCompany Secretary.If you feel that you cannot talkto them, contact the ExpolinkWhistleblowing hotline (seepage 17).Page 15

Halma Code of Conduct – September 2011CONFLICTS OF INTEREST( co ntinued)Guidance (continued)Personal relationshipsOpen and friendly relationships between colleagues helpcreate a good working environment. However, individualrelationships which become too close can lead to aperception of lack of objectivity or preferential treatment,especially if there is an immediate reporting relationship,and are best avoided.You should avoid personal relationships that mayconflict with your role or position within Halma – forexample if you have a buying role within Halma it wouldbe inappropriate for you to have a close personalrelationship with someone on the sales team from amajor supplier.Conflicts should be avoided if at all possible, but if they dooccur, the key things are:Recognise there is a conflict.Disclose it to your MD and DCE.Withdraw from any decision-making process affected bythe conflict.Page 16

Halma Code of Conduct – September 2011WHISTLEBLOWINGPrinciplesAll Halma employees and business partners are expected tomaintain the highest standards of integrity. If anyonebecomes aware of an instance of serious misbehaviour at aGroup company then they have a responsibility to help stopit. Serious misbehaviour includes:An action which is a criminal offence or breach of a legalobligation.An action that leads to a miscarriage of justice.An action which compromises the health and safety ofany individual.An action which causes damage to the environment.The deliberate concealment of information about any ofthe above.Additional sources ofinformationProcedure Note WB/1(Whistleblowing policy andprocedure) available on the HalmaIntranet (see page 3 for details ofhow to access).PolicyHalma believes that the correct approach is to raiseconcerns with the management of the company where themisbehaviour is occurring so that an appropriate localinvestigation can be carried out.However, if you have a strong reason for believing youcannot raise the matter locally, or where you believe thelocal response is insufficient, you should contact thecompany‟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 aconcern in good faith does not suffer any victimisation ordetriment. It fully endorses and will comply with any locallegislation that reinforces that position. However a concernthat is raised maliciously or for no good reason may lead todisciplinary action.GuidanceWhat 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 ofanything you report.Page 17

Halma Code of Conduct – September 2011WHISTLEBLOWING ( continued)Guidance (continued)How do I contact the hotline?Expolink provide local freephone numbers for most countriesor have a reverse charge (call collect) number for countrieswhere freephone numbers are not allowed. The hotline isavailable 24 hours a day, every day of the year (exceptChristmas Day).You can also report concerns via the Expolink website or byclicking on the link on the Halma website. Contact detailsare shown on page 20.What happens when I call?You will talk to one of Expolink‟s operators who will listen toand take written notes of your concern. The call will not berecorded. Expolink will then securely send a report to theHalma Company Secretary or the Halma Group FinanceDirector who will ensure that your concern is investigatedappropriately.Do I have to identify myself?Halma would rather that you did, since this makesinvestigating 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 whereyou work.Will my call be treated confidentially?Once Expolink have confirmed that Halma p.l.c. havereceived their report they will destroy all records of your call.Halma p.l.c. will maintain the confidentiality of the report asfar as is possible but you must be aware that, to carry out aproper investigation, some information may need to bedisclosed.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 aconcern without good reason or maliciously may lead todisciplinary action.Page 18

Halma Code of Conduct – September 2011WHISTLEBLOWING ( continued)Guidance (continued)How do I get feedback on my concern?As part of the hotline conversation the Expolink operator willask if you want to receive feedback. If so they will give youa security code and ask that you call back in 4 weeks,quoting the code, at which time they will be able to updateyou on progress. The 4 week delay is to allow time for aproper investigation to be carried out.Page 19

Halma Code of Conduct – September 2011CONTACT DETAILSHalmaHalma Company Secretary Tel: +44 (0)1494 721111Fax: +44(0)1494 728032Email: cosec@halma.comHalma websitewww.halma.comExpolinkCountryFreephone NumberAustralia 1800 121 889Belgium 0800 71025Brazil 0800 891 8807Canada 1888 268 5816ChinaChina (alternative)00800 3838 300010800 441 0078Czech Republic 800 142 428France 0800 900240Germany 0800 182 3246India 000 800 440 1286Netherlands 0800 022 9026New Zealand 0800 443 816Russia 810 800 2058 2044Singapore 800 4411 140Spain 900 944401Switzerland 0800 563823United Kingdom 0800 374199UAE (United Arab Emirates) 8000 44 138 73USA 1877 533 5310Calls from mobile phones are not free and charges will varydepending on your provider.Collect Call Number Tel: +44 (0)1249 661 808Expolink website (background) www.expolink.co.ukExpolink (Halma Hotline link) www.expolink.co.uk/halmaPage 20

Halma Code of ConductI acknowledge that I have received and read a copy of the Halma Code ofConduct.I understand the importance of the Code as a way of communicating Halma‟scommitment to ethical business activity and agree to comply with the Code‟srequirements at all times.Name: ………………………………….....Company: ………………………………...Position: …………………………………..Signed: ……………………………………Date: ………………………………………