Halma Code of Conduct - Riester

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