Halma Code of Conduct - Riester

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