Anti-Bribery & Corruption Policy
1 OUR COMMITTMENT
1.1 The Board of Halma p.l.c. has a zero-tolerance attitude towards bribery and corrupt practices in all the business dealings of Halma p.l.c., of its subsidiaries and operating units, and of its associates, in every country and jurisdiction in which the Group has activities. To reflect this attitude, the Board will:
- Constantly work toward maintaining and improving a culture of fair, honest and open business activity in all Halma operations and their associates.
- Require and ensure compliance with all international and national legal requirements in respect of corrupt practices throughout Halma’s worldwide operations.
- Provide adequate resources for the development of policies and procedures and their communication to the worldwide workforce, including training where needed, so that all employees have the required level of understanding together with the resources to allow them to comply with this policy.
2 OUR OBJECTIVES
2.1 In order to reduce the risk from bribery and corruption to an absolute minimum, Halma p.l.c. will:
- Periodically assess the risks to Halma’s operations from bribery and corrupt practices.
- Use that risk assessment to develop a proportionate and prioritised management plan to control the risk.
- Continually develop, monitor and improve systems and procedures to meet the management plan objectives.
3 OUR RESPONSIBILITIES
3.1 Responsibilities for managing the risk from bribery and corruption lie with all employees and associates of Halma businesses worldwide. Specifically:
- All officers, employees, consultants, contractors, suppliers, agents and other associates are expected to comply with legal obligations and the requirements of this bribery and corruption policy.
- The Board will develop and maintain a centrally coordinated approach to the management of bribery and corruption risk, communicating Group-wide policies, procedures and other tools to assist its operations in meeting their obligations.
- The Board devolves the responsibility for implementing the policies and procedures to the Chairman (Divisional Chief Executive) and the Managing Directors of each Group company.
4 OUR EXPECTATIONS FOR COMMUNICATION
4.1 Any breach of the policy must be recorded and reported to allow appropriate corrective action and management of the consequences. There is no materiality or de minimus associated with this requirement.
4.2 All employees are encouraged and expected to:
- Discuss areas of concern with their managers and colleagues and seek further advice and support where needed.
- Report specific concerns and instances of non-compliance to their line managers and up through the management structure if needed.
- If it is felt necessary, make use of the Group’s whistleblowing procedure.