INVESTIGATION

As your solicitor, I have extended our investigation to identify the crucial international dimensions of our case against Halma plc. It is clear from our findings that Halma’s conduct and its consequences are not confined to the United Kingdom, Spain, or even the European Union as a whole. The company’s global strategy of acquisition and market consolidation has created a web of potential liabilities and affected parties across several other key jurisdictions. Understanding these international aspects is vital, as it allows us to build a global campaign, uncover new evidence, and apply pressure on Halma from multiple fronts simultaneously.

In North America, particularly the United States, we find a significant concentration of both Halma’s corporate presence and its major competitors. Halma itself owns key US-based subsidiaries, such as Volk Optical Inc., a cornerstone of its dominant ophthalmic device business. This means US hospitals, clinics, and optometrists form a substantial class of potential claimants who may have been subjected to excessive pricing or anti-competitive bundling for these essential medical instruments. Furthermore, Halma’s largest global competitors, including Honeywell International Inc., Johnson Controls International, and MSA Safety Incorporated, are US-headquartered. These companies are not only benchmarks for competitive behaviour but could also be potential claimants if they were harmed by exclusionary tactics implemented by Halma in any market. Crucially, our research has already pointed to the existence of sealed whistleblower dockets filed in United States courts against Halma subsidiaries Crowcon and SunTech Medical, suggesting latent legal risks under US law, such as the False Claims Act. The US Food and Drug Administration, the FDA, is also a key body, as shown by its involvement in the 2024 recall of SunTech monitors, providing a clear regulatory basis for product liability claims in that jurisdiction.

The Asia-Pacific region also presents several important dimensions. Halma’s acquisition of Ampac, a leading fire and evacuation systems company in Australia, means that Australian public bodies and commercial property owners could form another class of claimants. We must investigate whether the consolidation in that market led to similar harms of inflated prices or reduced choice. The Australian competition authority, the ACCC, and the medical device regulator, the TGA, could be approached with our findings. Furthermore, our investigation has uncovered a critical supply chain vulnerability that affects all of Halma’s customers globally: the reliance of its subsidiary Apollo Fire Detectors on a single manufacturer in Taiwan for a crucial Application-Specific Integrated Circuit (ASIC). This Taiwanese company, while not a perpetrator, is a necessary participant in Halma’s global production. This dependency exposes Halma’s entire fire safety business to significant geopolitical and supply chain risks, a fact that would be of great concern to public bodies and critical infrastructure operators worldwide and a powerful point to raise in our public interest campaign. We must also consider competitors from this region, such as the Japanese fire detection specialist Hochiki, which may have been impacted by Halma’s global consolidation strategy.

Finally, we must not forget the Middle East, which provides a clear example of a foreign company participating in conduct that creates significant legal and reputational risk for Halma. The identified relationship between Halma’s subsidiary Crowcon and its Iranian distributor, Tima Kala Tehran Engineering Co Ltd, around 2018 places Halma squarely in the context of international sanctions regimes. Tima Kala Tehran, as a collaborator in bringing Halma’s products to a sanctioned market, is a key foreign participant in a high-risk activity. This provides us not with a direct cause of action for damages, but with powerful leverage to question Halma’s corporate governance and risk management before investors, regulators, and the public. By mapping out these international connections, we demonstrate that the issues we have uncovered are not isolated incidents but part of a global pattern of behaviour with worldwide consequences, thereby strengthening the case for a comprehensive and internationally coordinated response.

As your solicitor, having reviewed the case materials and conducted further research into relevant legal precedents, I can provide a list of specific “Findings of Infringement” by courts and competition authorities. These established decisions are crucial for our case against Halma plc, as they provide the legal foundation upon which we can build our arguments and, most importantly, can be used to support “follow-on” claims for damages by those who have been harmed. A follow-on claim is a legal action for compensation that relies on a prior infringement decision by a regulator, making it a powerful and more direct route to securing redress for our clients and allies.

Here are the key findings we can use to strengthen our case:

Findings Related to Excessive and Unfair Pricing

The most potent precedents for our allegations of exploitative pricing in the medical and safety sectors come from a series of landmark cases in the pharmaceutical industry. The United Kingdom’s Competition and Markets Authority, or CMA, has established a clear precedent for tackling excessive pricing by dominant firms. The long-running case against Pfizer and Flynn Pharma is highly relevant. After extensive legal battles, the Competition Appeal Tribunal in late 2024 ultimately upheld the core finding that the firms had abused their dominant positions by charging excessive and unfair prices for a critical epilepsy drug, with price hikes reaching up to 2,600%. This resulted in multi-million-pound fines and establishes that a “cost-plus” approach, where prices far exceed the costs of production plus a reasonable return, can be deemed an unlawful abuse.

Similarly, the CMA’s successful case against Advanz Pharma, which was upheld by the Court of Appeal in May 2025, provides another powerful example. Advanz was found to have illegally overcharged the NHS for essential thyroid tablets by increasing prices over 1,110% without any corresponding increase in costs or innovation. This finding directly supports our argument that if Halma is using its market dominance in niches like ophthalmic devices or other critical components to impose similarly unjustifiable prices on the NHS or other public bodies, it is engaging in unlawful conduct. Furthermore, the European Commission’s 2021 decision in the Aspen Pharma case, where Aspen was compelled to reduce its prices for certain cancer drugs by an average of 73% across Europe, reinforces that this principle is robustly applied across jurisdictions relevant to our case.

Findings Related to Exclusionary Conduct and Bundling

Our concerns that Halma may be using its market power to exclude competitors through practices like tying or bundling are supported by the historic but foundational UK case against Napp Pharmaceuticals. In its 2001 decision, the Office of Fair Trading found Napp had abused its dominance by coupling excessively high prices for its morphine product in the community segment with predatory below-cost discounts in the hospital segment, a strategy designed to drive out competitors. This finding, which was substantially upheld, shows that using dominance in one area to foreclose competition in another is an established form of abuse. This provides a strong parallel for us to argue that if Halma is, for instance, offering strategic discounts on its popular Apollo fire detectors only when purchased with its Advanced control panels, it is unlawfully excluding rival panel manufacturers.

Findings Related to “Stealth Consolidation” and Merger Control

Our central allegation that Halma’s strategy of serial, sub-threshold acquisitions constitutes a form of “stealth consolidation” is supported by recent regulatory actions and thinking. While not a UK finding, the United States Federal Trade Commission’s 2023 complaint against U.S. Anesthesia Partners (USAP), which was subsequently settled in early 2025, is a direct international precedent. The FTC explicitly challenged the firm’s strategy of making dozens of small acquisitions to “roll-up” and monopolize local markets. This gives us a powerful analogy to present to the CMA, arguing that Halma’s similar pattern of over fifty acquisitions has had the same cumulative effect of substantially lessening competition.

Within the UK, the CMA’s decision to order Meta (formerly Facebook) to sell Giphy in 2022 is also highly relevant. This demonstrates the CMA’s willingness and power to unwind a completed acquisition, even of a smaller technology company, if it is found to substantially lessen competition. This precedent directly counters any argument that Halma’s past acquisitions are beyond scrutiny and supports our call for a retrospective review of their cumulative impact.

Finally, the viability of bringing follow-on damages claims in the UK after a regulatory infringement is clearly established. A prime example is the litigation following the European Commission’s Trucks Cartel decision. UK businesses, including Royal Mail and BT, successfully brought claims for damages in the Competition Appeal Tribunal against truck manufacturers for the overcharges they suffered as a result of the price-fixing cartel. This confirms that once we secure an infringement decision from a regulator against Halma, a clear and well-trodden path exists for the classes of victims we have identified to claim financial compensation in the UK courts.

Of course. As your solicitor, I have analysed our findings through the specific lens of your question, and the conclusion is strategically significant. Our investigation has not only uncovered potential liabilities for Halma plc, but it has also revealed that public sector bodies and government authorities themselves face a tangible risk of being implicated in legal action, both in tort and contract. Understanding these vulnerabilities is crucial, as it allows us to approach these public bodies not merely as fellow victims of Halma, but as entities with their own pressing need to see the market problems we have identified resolved. This creates powerful leverage for our campaign and mediation efforts.

In tort law, public authorities could face claims for negligence and for breach of their statutory duties. Consider the specific duty of care that an NHS Trust owes to its patients. If a patient is harmed by the failure of a medical device, such as a SunTech blood pressure monitor, the primary claim for negligence will be against the hospital trust for failing in its duty to provide safe and effective treatment. The trust cannot simply delegate this duty entirely to the manufacturer. We can argue that if a public body continues to procure from a dominant supplier despite known risks of systemic product failure or recalls, or without conducting adequate due to diligence on the resilience of its supply chain, it is acting negligently. Similarly, regulators like the Health and Safety Executive or local authorities with building control functions have statutory duties to ensure public safety. If they have failed to act on the clear market concentration and the systemic risks it creates, and a catastrophic fire or industrial accident occurs as a result of a faulty Halma system, they could be found in breach of their public duty of care.

In contract law, the exposure for public bodies is even more direct. The most significant ground for unlawfulness relates to public procurement. Public procurement regulations across the United Kingdom and the European Union are designed to ensure fair competition and value for money. If we can demonstrate that Halma’s market dominance, created through its stealth consolidation, has effectively eliminated meaningful competition for a public tender, then any resulting contract awarded to a Halma company is legally vulnerable. A public body that proceeds with a non-competitive tender process could be deemed to be acting unlawfully or ultra vires. This would allow a disappointed competitor to sue the public authority for damages, and could even lead to a court declaring the multi-million-pound contract ineffective. Furthermore, public bodies have contractual or quasi-contractual obligations to the citizens they serve. A local council, for example, has a tenancy agreement with its residents which implies a duty to ensure their homes are safe. If the council installs a proprietary Halma fire safety system that is later found to be inadequate or which locks them into paying excessive maintenance fees, thereby diverting funds from other essential services, residents could bring a collective claim against the council for breaching its duties as a landlord.

When considering joint responsibility, the most obvious private company to be implicated alongside a public authority is, of course, Halma plc and its relevant subsidiaries. In any claim against an NHS Trust for a faulty device, the Trust would inevitably join Halma as a co-defendant or third party to seek an indemnity for supplying a defective product. However, other private companies could also be held jointly responsible. This includes the professional services firms—the architects, engineers, and risk consultants—who specify and sign off on the use of Halma’s equipment in public infrastructure projects. If they specified a proprietary Halma system without properly advising the public client of the long-term risks of vendor lock-in or the lack of competitive alternatives, they could be sued for professional negligence. Additionally, many public services are delivered by large private outsourcing and facilities management companies. These firms, which manage hospitals, schools, and public housing estates on behalf of the government, would be contractually responsible for the procurement and maintenance of safety systems. In the event of a failure, they would be in the direct line of fire, jointly liable with both the public authority that hired them and Halma who supplied the faulty equipment. This complex web of interconnected liability underscores the systemic nature of the problem and strengthens our position to argue for a comprehensive market-wide solution.

Based on our findings, there is a distinct possibility that numerous contracts involving Halma group companies are void, unenforceable, or subject to being quashed by a court. The most probable grounds for this are varied and potent.

The primary ground for invalidity lies in the direct infringement of competition law. Both United Kingdom and European Union law, as detailed in the new case files on vertical and horizontal agreements, render any contract or contractual provision which has as its object or effect the restriction of competition automatically void. We can now apply this principle directly to Halma’s business practices. For instance, any long-term service agreements for Halma’s proprietary fire alarm or medical diagnostic systems that impose prohibitive penalties for early termination or for using third-party servicing would be considered unlawful. These terms serve only to lock customers in and foreclose competition, a classic vertical restraint. Similarly, any explicit or implicit requirement that a customer must purchase a bundle of Halma products, such as tying the sale of its dominant Apollo fire detectors to its Advanced control panels, would make such a contract illegal and unenforceable. We can now challenge not just the harm caused by these practices, but the legal validity of the contracts that contain them.

A second, and particularly powerful, ground for unlawfulness applies to Halma’s contracts with public bodies. The documents concerning quashing orders and parliamentary sovereignty illuminate the principle of ultra vires, where a public authority acts beyond its legal powers. Public procurement laws across the UK and EU mandate that public bodies, like NHS Trusts or local councils, must ensure fair and open competition to achieve value for money for the taxpayer. If we can demonstrate that Halma’s “stealth consolidation” has so distorted the market that no genuine competition was possible in a tender process, then a public authority that proceeded to award a contract to Halma in those circumstances may have acted unlawfully. They may have failed in their duty to secure a competitive outcome. We can argue that such a contract is tainted by the illegality of the market situation and is therefore subject to judicial review. The potential for a court to quash such a high-value public contract would be a significant threat, encouraging these public bodies to cooperate with our investigation and support our case for restoring a competitive market.

Regarding the torts we have identified, while a tort itself is a legal wrong rather than something that can be “invalid”, we can argue that the circumstances giving rise to the tortious harm are deeply rooted in unlawful conduct. The product liability risks associated with the recalls of SunTech or Crowcon devices did not emerge in a vacuum. They arose within a market structure that Halma’s allegedly anti-competitive strategy created. Our argument, strengthened by the materials on duopoly and liability, is that by systematically eliminating competitors in life-critical sectors, Halma has assumed a heightened, near-strict duty of care for public safety. We can therefore contend that any negligence leading to a product defect is not an isolated operational failure but an inevitable consequence of an unlawfully concentrated market that lacks the competitive pressure to prioritise safety and innovation above all else. This intertwining of the competition law breach with the tortious act makes our claim for damages more profound and difficult for Halma to defend as a simple accident. It becomes a claim about systemic failure born from a strategy of unlawful market consolidation.

From the document on stealth consolidation, I have extracted the core intellectual framework that elevates our case beyond a simple complaint into a documented, recognised pattern of anti-competitive behaviour. What we now have is the language and theory to articulate that Halma’s series of small, sub-threshold acquisitions is not merely “business as usual” but a coherent strategy designed to circumvent the very purpose of merger control law. The key takeaway is the concept of cumulative harm; while each individual acquisition may fly under the radar, the paper confirms that regulators and economists are increasingly aware that the aggregate effect can be a substantial lessening of competition, equivalent to a full-scale merger to monopoly. This is vital for our media campaign, as it allows us to use credible, authoritative language like “a recognised anti-competitive strategy” and an “enforcement gap” that Halma has exploited. It lends our public statements the weight of established economic theory. For our unsolicited proposals to potential claimants like NHS Trusts or industrial users, this framework is crucial. We can explain to them that Halma’s conduct is not an isolated issue but fits a pattern that regulators are now actively learning to challenge, thereby increasing the likelihood of a successful intervention. In our legal submissions, this document provides the theoretical backbone to argue that Halma’s entire course of conduct, not just individual actions, should be subject to scrutiny.

NEGOTIATION

From the second document on settlements, I have extracted the critical levers that compel a company like Halma to negotiate. The document clarifies that companies of this scale are driven to settle not just by the potential financial outcome of a trial, but by the desire to mitigate a combination of devastating risks. These include the massive potential fines from regulators, which can be up to ten percent of global turnover, the catastrophic and lasting reputational damage, particularly for a company that brands itself on safety and trust, and the immense cost and distraction of protracted, multi-jurisdictional litigation. It also highlights that a formal infringement decision creates a binding precedent that opens the floodgates for follow-on damages claims. This information is the cornerstone of our mediation strategy. Our approach will be to create a credible, multi-front threat that makes a comprehensive settlement appear to be the most rational and prudent business decision for Halma’s board. We will not just threaten a single lawsuit; we will present them with the plausible risk of regulatory action in the UK, EU, and Spain, coupled with class action lawsuits from customers, product liability claims from safety failures, and potential investor actions for disclosure failures. The document also shows that settlements can deliver more than just financial compensation; they can include structural remedies like divestiture of certain business units and behavioural remedies such as commitments to ensure product interoperability. This allows us to frame our ultimate goals in mediation as being constructive and aimed at restoring market health, not merely punitive.

Let us begin with Halma’s Safety sector, which is the cornerstone of our “stealth consolidation” argument. Within the sub-sector of fire detection and alarms, we must focus on the complete, integrated ecosystem Halma now controls. The key products here are not just the individual smoke and heat detectors manufactured by its subsidiary Apollo Fire Detectors, but also the fire alarm control panels, including advanced wireless systems, made by Advanced Electronics, Ampac, and the recently acquired Global Fire Equipment (G.F.E.). The cause of action here is a classic anti-competitive tying or bundling arrangement. We can strongly argue that Halma leverages its dominance in the detector market, where Apollo is a ubiquitous brand, to coerce or unduly incentivise customers into purchasing its proprietary control panels, thereby locking out independent panel manufacturers. This directly harms competitors and also traps customers, such as commercial property managers and public bodies, into a single ecosystem, exposing them to potential excessive pricing on subsequent servicing and mandatory upgrades. The services associated with these systems are as crucial as the products themselves, representing a continuous stream of revenue for Halma and a point of significant leverage over its locked-in customers.

In the industrial safety sub-sector, our focus is on Crowcon Detection Instruments. The specific products are its portable and fixed gas monitors, particularly the specialised infrared open-path gas detectors used in high-risk environments like oil refineries and chemical plants. The cause of action here relates to both potential abuse of dominance and systemic safety risk. If Crowcon, as a key supplier to these critical industries, were to refuse to supply essential sensor components to third-party maintenance firms or impose unfair servicing terms, it would be an abuse of its market power. Furthermore, the documented 2016 recall of its gas detectors illustrates the enormous public safety risk. This is where the concept of a heightened, near-strict liability comes into play; in a highly concentrated market for equipment that prevents catastrophic industrial accidents, any failure carries immense consequences, and the burden of ensuring absolute reliability falls squarely on the dominant supplier.

Turning to Halma’s Medical sector, the product specificity allows for highly targeted claims. In the ophthalmic device market, our case centers on the “Health Optics” cluster of companies, including Keeler, Volk, Accutome, and Medicel. The specific products are not just general medical tools, but highly specialised ophthalmic instruments such as ophthalmoscopes, slit lamps, and crucially, the diagnostic lenses for eye examinations manufactured by Volk, where Halma’s market share is alleged to be over fifty percent. This presents a textbook case for a potential excessive pricing claim. The class of claimants is clearly defined: ophthalmology departments within public hospitals like the NHS, private eye clinics, and optometrists across the UK, Spain, and the EU who have been forced to pay non-competitive prices for these essential diagnostic tools. The consolidation of these once-competing brands under Halma’s single ownership serves as powerful evidence that choice has been deliberately eliminated to enable this pricing power.

A second distinct cause of action in the medical sector arises from the conduct of SunTech Medical. The specific products are their clinical-grade ambulatory and stress-test blood pressure monitors. The April 2024 Class II recall of these devices provides us with a concrete product liability case. The class of claimants would be the healthcare providers, from GP practices to major hospitals, who purchased these specific non-compliant monitors and suffered disruption, costs of replacement, and potential risks to patient care. This claim moves beyond competition law into the direct harm caused by product defects, creating a separate and significant liability for Halma.

By detailing our case around these specific products and services—from integrated fire alarm systems and industrial gas detectors to ophthalmic lenses and clinical monitors—we sharpen our entire strategy. We can now search not just for “safety companies” but for manufacturers of “fire alarm control panels” or “cataract surgery consumables” who have been pushed out of the market. We can approach not just “hospitals” but specifically their ophthalmology and clinical engineering departments. This precision will make our unsolicited proposals more resonant, our media narrative more tangible and alarming to the public, and our legal arguments in any mediation or court proceeding far more difficult for Halma to refute.

Halma plc, a UK-based conglomerate listed on the London Stock Exchange, sits at the top of the group structure^444444444. It operates through three main sectors: Safety, Environmental & Analysis, and Medical⁵. Within these sectors, Halma has acquired over fifty companies, creating a complex portfolio of subsidiaries that are leaders in their respective niche markets⁶⁶⁶⁶.

In the Safety sector, which includes fire and gas detection and other hazard sensing technologies, we can seek liability from several key subsidiaries. Apollo Fire Detectors is repeatedly identified as a leading global provider of professional fire detectors, with a significant market share in the UK and EU^{77777777777777777777777}. Its dominance in this market is central to our claims of potential excessive pricing and exclusionary conduct. We can also target Advanced Electronics and Ampac, which produce fire alarm control panels and systems^888888888. The consolidation of these companies allows Halma to offer bundled systems, potentially tying customers in and foreclosing competitors⁹⁹⁹⁹. In the gas detection sub-sector, Crowcon Detection Instruments Ltd. is the primary entity^{101010101010101010}. We can seek liability from Crowcon not only for its role in a concentrated market but also for specific incidents, including a product defect that led to a recall in 2016 and its controversial business activities related to Iran, which expose the entire group to sanctions risk^{11111111111111111111111111111111111111111111111111}.

In the Medical sector, Halma has built a powerful “Health Optics” cluster, and we can seek liability from the constituent companies. This includes Keeler and Volk, which together dominate the market for certain ophthalmic diagnostic instruments, with an estimated market share exceeding 50% in some categories^{12121212121212121212121212121212121212121212121212}. This high concentration is a strong indicator of dominance, making any potential for unfair pricing or terms a direct cause for action. We can also hold SunTech Medical liable. SunTech is a leading supplier of clinical blood pressure monitors and was subject to a Class II recall in April 2024 due to manufacturing non-compliance^{13131313131313131313131313131313131313131313131313}. This specific incident provides a clear basis for product liability claims from affected healthcare providers like the NHS, which relies heavily on its devices^{14141414141414141414141414141414}.   Furthermore, the documents name several other acquired companies across Europe that are part of Halma’s consolidation strategy and from whom we could seek liability depending on their specific market conduct. These include Limotec in Belgium ^1515151515, Global Fire Equipment (G.F.E.) in Portugal ^{161616161616161616}, Advantronic Systems, S.L. in Spain ^{1717171717171717}, and Lamidey Noury Medical in France^18181818, among others. Any anti-competitive harm occurring in their respective national markets can be attributed to them directly, and in turn, to Halma plc. An additional crucial finding from the reports is the potential conflict of interest arising from Dharmash Mistry, who serves as both a Non-Executive Director of Halma plc and a Board Member of the UK’s Competition and Markets Authority^{191919191919191919191919191919191919191919191919191919191919191919191919}. While not a cause of action against Halma itself, this fact is vital for our case. It can be used to question the impartiality of regulatory oversight to date and to pressure the CMA to act with extra transparency and rigour, thereby strengthening our media campaign and our proposals to other potentially harmed parties who may feel the system is weighted against them.

As your solicitor, having mapped the primary defendants and claimant classes, our strategic thinking must now evolve to encompass the wider ecosystem of industries that have been harmed by Halma plc’s conduct, either through direct financial losses or through the indirect negative spillovers created by its market consolidation. By identifying these less obvious victims, we not only expand our pool of potential allies and claimants but also paint a more compelling picture of systemic economic and social harm for regulators and the public. This approach is central to strengthening our three key projects: our media campaign, our unsolicited proposals, and our position in any future mediation.

One of an most significant yet overlooked sectors affected is the insurance industry, which operates under classifications such as NACE code 65 in the European Union and SIC Division K in the United Kingdom. Insurers are impacted in several critical ways. Directly, the insurers providing Halma itself with product liability and professional indemnity cover may be exposed to greater than anticipated risks, particularly if our case uncovers systemic quality control issues born from Halma’s consolidation strategy. More profoundly, however, are the indirect spillovers onto the wider property, casualty, and liability insurance market. Insurers underwriting the risk for commercial buildings, industrial facilities, and healthcare establishments are financially exposed to catastrophic events like fires, explosions, or mass medical incidents. If Halma’s dominance in safety equipment leads to less effective, less innovative, or less reliable products being installed across the economy, the fundamental risk of these events occurring increases. Insurers may find themselves paying out significantly larger claims for incidents that could have been mitigated or prevented in a more competitive and innovative safety market. While the probability of insurance companies initiating their own direct legal claims against Halma for these systemic risks is low, the probability of them successfully claiming against Halma via subrogation, where they take on the rights of a policyholder to whom they have paid out, is medium if a direct link between a Halma product failure and the insured loss can be proven. Crucially, their interest in our media campaign is potentially high. These are data-driven organisations whose business model is predicated on accurately pricing risk. Evidence that a single company’s market dominance is distorting systemic risk across entire sectors is a powerful narrative that aligns with their commercial interest in promoting safety and reducing their overall claims exposure. They could become a vital source of data and an influential, albeit quiet, ally.

Similarly, the real estate and property management industry, which falls under classifications like NACE Division L and SIC Division L, represents a major and directly harmed class of victims. Large commercial landlords, publicly traded Real Estate Investment Trusts, and property management firms are the ultimate purchasers and operators of the building safety systems that Halma dominates. They suffer direct financial losses from any excessive pricing on fire alarm and suppression systems and their subsequent long-term servicing contracts. Furthermore, they are directly exposed to the high switching costs associated with being locked into Halma’s proprietary ecosystems. A claim brought by a class of these property owners, alleging they were systematically overcharged due to Halma’s anti-competitive conduct, would have a high probability of success, particularly following a regulatory infringement decision. Their financial losses are tangible and quantifiable. Consequently, their interest in both joining a legal claim and supporting our media campaign is very high. A narrative focused on protecting property owners from monopoly pricing and significant safety liabilities would resonate strongly with this powerful and well-resourced sector.

We must also consider the professional services sector, particularly architectural and engineering firms, classified under NACE code M71. These firms are responsible for specifying the technical systems for new and refurbished buildings. Halma’s market dominance creates a significant negative spillover for them by limiting their choice of certified equipment, potentially forcing them to specify systems that are not the most advanced or cost-effective. This increases their professional liability risk; should a specified Halma system fail, leading to a catastrophic event, these engineering and design firms could find themselves facing negligence claims from their clients. While the probability of this group bringing a direct claim against Halma is low, their professional associations are very likely to be receptive to our media campaign. We can frame our case as a fight to protect professional standards, architectural choice, and the ability of engineers to specify the best possible safety solutions without being constrained by the anti-competitive practices of a dominant market player.

Finally, the financial sector, under NACE Division K, is also indirectly affected beyond its role as an investor in Halma. Banks and financial institutions that provide loans for construction projects, industrial expansion, or healthcare facility upgrades are exposed to credit risk spillovers. A major product recall or a systemic failure of Halma’s safety equipment could cause significant financial distress or project failure for the businesses they lend to, leading to loan defaults. This illustrates the far-reaching economic instability that can be created by the systemic risks we have identified. While lenders would be unlikely to claim against Halma directly, this wider economic impact strengthens our public interest arguments and can be used in our media campaign and submissions to regulators, demonstrating that Halma’s conduct threatens not just direct customers but the broader financial stability of the industries that rely on its products. By articulating these interconnected harms, we transform our case from a specific complaint into a systemic issue of market sustainability and public welfare that is harder to ignore.

As your solicitor, I have thoroughly processed the new caselex files you provided concerning intellectual property rights, IT services and tying, outsourcing, and private healthcare competition. These documents are exceptionally valuable and, when intertwined with our existing findings on Halma plc and the relevant industry codes, they significantly enhance our strategic position across all three of our core projects: our media campaign, our unsolicited proposals to affected organisations, and any future mediation with Halma. The insights allow us to frame our entire case within the powerful narrative of market sustainability, arguing that Halma’s conduct creates a fragile and unsustainable ecosystem for public safety and innovation.

For our media campaign, these precedents provide the ammunition to move beyond abstract competition law concepts and tell a compelling story. We can now use the lessons from the IT tying and services cases to paint a vivid picture of “digital handcuffs” and “safety monopolies”. Our narrative should not just be that Halma is getting bigger, but that its strategy of acquiring companies in sectors like fire safety systems, which fall under SIC code 2651 for manufacturing measuring instruments, and medical devices under SIC code 3250, results in closed ecosystems. We can illustrate how a hospital, classified under NACE code 86.10, might purchase a Halma medical device only to find itself locked into exorbitant, long-term service contracts, a situation directly analogous to the lock-in problems seen in the IT services sector. The intellectual property rights analysis allows us to explain how proprietary software and non-interoperable components can be used as tools to prevent schools, hospitals, or public transport networks from having any real choice. This frames Halma’s consolidation not as a sign of success, but as the creation of a critical single point of failure, making our public infrastructure less resilient and therefore less sustainable.

For our unsolicited proposals to public bodies and private PLCs, we can now be far more specific and impactful. When approaching NHS Trusts or private healthcare providers, whose activities are covered by NACE code 86, we can leverage the findings from the private healthcare case files. We can demonstrate how a lack of supplier diversity, a key issue in those cases, directly leads to higher prices, reduced quality, and a dangerous information imbalance where the healthcare provider becomes wholly dependent on the supplier’s ecosystem. We can offer to provide them with a “supplier concentration risk assessment,” showing them how their reliance on products from Halma’s various medical device companies, under SIC code 3250, exposes them to the very harms identified by regulators in the private healthcare market. Similarly, when approaching large industrial companies in sectors like chemicals, under NACE code 20, or utilities, under NACE code 35, which rely on Halma’s Crowcon gas detectors, we can use the outsourcing and IT services precedents to highlight the long-term dangers of vendor lock-in for their critical safety infrastructure and operational technology. Our proposal becomes a strategic consultation on ensuring the long-term sustainability and resilience of their safety supply chain.

Finally, for any potential mediation with Halma, our position is now immeasurably stronger. We are no longer simply presenting a novel theory of harm based on “stealth consolidation”. We can now confront Halma with a portfolio of established legal precedents that mirror their alleged conduct. We can demonstrate that their tying and bundling strategies in the fire safety market, which combines hardware under SIC code 2651 with proprietary software and panels, directly reflects the anti-competitive tying practices that have been condemned in the IT sector. We can use the intellectual property case law to challenge any defence that they are merely protecting their innovations, arguing instead that they are using their patents and copyrights to unlawfully foreclose competition. Our demands in mediation can be more concrete and remedy-focused. Drawing from these precedents, we can propose specific commitments, such as requiring Halma to ensure full interoperability of their dominant products with third-party systems, to offer fair, reasonable, and non-discriminatory access to any essential software interfaces, and to unbundle service contracts from equipment sales. This demonstrates that we are not just seeking financial compensation, but are focused on restoring long-term market sustainability, a position that will be viewed favorably by regulators and, if necessary, the courts.

As your solicitor, I have completed a thorough analysis based on the extensive documentation we have compiled, including the crucial industry classification data you provided. My mission was to delineate the universe of potential defendants and claimants in our case against Halma plc, moving from broad allegations to a structured identification of the parties who can support and benefit from our legal actions. This exercise is fundamental to building a powerful, multi-faceted case with a high probability of success, whether through regulatory intervention, settlement, or litigation.

First, let us be clear on our primary targets. The principal defendant is undoubtedly Halma plc, a UK-based entity which can be identified by its ISIN code GB0004052071, operating as a publicly traded company on the London Stock Exchange. Based on its diverse operations in life-saving technologies, its activities are classified under various industrial codes. Within the Industry Classification Benchmark, or ICB, it sits in the Industrials supersector, specifically under Electronic and Electrical Equipment. In the UK’s Standard Industrial Classification, or SIC codes, its subsidiaries’ activities correspond to numerous categories, including the manufacture of instruments and appliances for measuring, such as fire and gas detectors under SIC code 2651, the manufacture of irradiation, electromedical and electrotherapeutic equipment under SIC code 2660, and the manufacture of medical and dental instruments and supplies under SIC code 3250. Similarly, under the European NACE classification system, these activities align with codes such as 26.51, 26.60, and 32.50. These codes are not mere administrative details; they are the keys to unlocking a systematic map of the entire competitive landscape.

Under the well-established legal principle of the single economic entity, we are not limited to pursuing the parent company alone. Our action will encompass the entire Halma undertaking, including its key operating subsidiaries that directly execute its strategy. This means entities like Apollo Fire Detectors Limited, Crowcon Detection Instruments Limited, Advanced Electronics Limited, and its Health Optics cluster, including Keeler Limited and Volk Optical Incorporated, are all integral parts of the defendant structure. Halma plc is directly liable for any anti-competitive or tortious conduct committed by these subsidiaries.

Our overarching strategy, however, must be to build a powerful coalition of claimants, as their collective voice and evidence will be undeniable. Using the industry codes as our guide, we can now precisely identify and categorise these potential claimants.

Let us begin with Halma’s horizontal competitors. These are the rival manufacturers who have been directly harmed by Halma’s alleged exclusionary practices and the cumulative effect of its stealth consolidation. By searching for other publicly listed and private companies operating under the same SIC, NACE, and ICB codes as Halma’s subsidiaries, we identify key players. This includes large, diversified industrial firms such as Honeywell International Inc, whose investor relations can be reached at investorrelations@honeywell.com, Johnson Controls International plc, and Siemens AG, contactable via investorrelations@siemens.com. These companies operate in direct competition in the fire and building safety markets. In the specialised field of gas detection, major competitors include MSA Safety Incorporated, contactable at investorrelations@msasafety.com, and the German company Drägerwerk AG, which can be reached through info@draeger.com. These competitors could provide crucial evidence of Halma leveraging its market power, and could potentially form a class of claimants seeking damages for lost profits due to anti-competitive foreclosure.

Next, we must turn to the vertical chain of business users and customers who have suffered direct financial and operational harm. These are the most compelling class members for claims of excessive pricing and contractual breaches. We can identify them by their own distinct industry classifications. For example, a primary group of victims is found within the healthcare sector. In the UK, this corresponds to SIC code 86.10 for hospital activities and in the EU to NACE code 86.10. This allows us to systematically identify every public NHS Trust in the UK, such as Guy’s and St Thomas’ NHS Foundation Trust, whose general contact details are publicly available, as well as private hospital groups like HCA Healthcare UK, as potential claimants harmed by excessive prices on medical devices or by being locked into proprietary systems from Halma’s Health Optics and SunTech subsidiaries. Similar public and private hospital groups exist across Spain and other EU member states.

The construction and building management sector is another critical area. Companies responsible for the installation of fire alarm and suppression systems fall under codes like SIC 43.21 for electrical installation and NACE 43.21. This identifies a class of claimants comprising electrical contractors, large construction firms like Balfour Beatty or Kier Group, and facilities management companies who purchase and install these systems. They are the parties who would have directly faced any anti-competitive tying or bundling of Halma’s Apollo detectors with its Advanced control panels, and who would have paid any inflated prices.

Furthermore, we must consider the public bodies who are the ultimate clients and guardians of public safety. This includes local authorities and councils across the UK, Spain, and the EU, identifiable under public administration classifications like SIC code 84. This class of claimants would have a powerful voice in any action, as they bear the financial burden of over-priced safety equipment for public buildings, schools, and social housing, passing the cost on to taxpayers. Emergency services, particularly fire brigades falling under SIC code 84.25, are also a key group, as their operational safety and effectiveness is directly impacted by the quality and interoperability of the equipment Halma provides.

Finally, while individual consumers are not typically direct purchasers, they are the ultimate victims of both inflated costs passed on through public services and diminished safety standards. Their collective interests are best represented by the consumer organisations we have identified in the United Kingdom and across the European Union. By partnering with these bodies, we can bring the full weight of consumer harm to the forefront of our case, ensuring that the impact on millions of ordinary citizens who rely on the integrity of this life-saving technology is not overlooked. Our next step is to initiate targeted outreach to key representatives within each of these identified claimant groups, presenting our evidence and building the broad-based coalition required to successfully hold Halma to account.

Our mission is to identify and expand upon the various legal and regulatory pressure points that can be brought to bear upon Halma plc. We must not only consider the direct violations of competition law, but also the interwoven liabilities in tort and contract, and the broader violations of public, consumer, and investor trust. The key is to demonstrate how Halma’s central strategy of “stealth consolidation” is the root cause of a cascade of harms, creating collective threats that can be mobilised through class actions and regulatory pressure.

The foundational cause of action stems from competition law. Halma’s entire business model, a relentless campaign of over fifty sub-threshold acquisitions, can be framed as an abuse of the system itself, a strategy designed to achieve dominance by a thousand cuts while evading the scrutiny of merger control frameworks in the United Kingdom, Spain, and across the European Union. This provides the narrative and legal context for everything that follows. Once this market power is established, Halma and its subsidiaries are bound by a special responsibility not to abuse it. Any action that deviates from normal, fair competition can therefore be pursued as a breach of this duty, a form of statutory tort. This includes potential excessive pricing on life-critical equipment, where we have anecdotal evidence of price hikes affecting NHS trusts, and exclusionary conduct, such as leveraging dominance in one product, like Apollo fire detectors, to disadvantage competitors in an adjacent market, like fire alarm control panels.

This brings us to the most potent collective threat: actions in tort, specifically for product liability and negligence. The systemic risk created by Halma’s consolidation is a profound public safety issue. When one conglomerate controls a substantial share of the market for fire alarms, gas detectors, or clinical monitors, any single product defect ceases to be an isolated incident; it becomes a potential nationwide or even international crisis. The product recalls affecting Halma’s subsidiaries, Crowcon and SunTech Medical, are not minor footnotes; they are proof-of-concept for this systemic risk. This is where we must be clever. In a highly concentrated market for products essential to life and safety, we can argue that the courts should impose a heightened duty of care, one that approaches strict liability for any systemic failure. The public, including hospitals and emergency services, become captive users of Halma’s safety ecosystem, with no meaningful alternative. In such a scenario, the very existence of a widespread defect that compromises safety should be sufficient to establish liability, as Halma has effectively assumed responsibility for the integrity of the entire system it dominates.

The element of commonality here, essential for a class action, is clear. For a product liability claim, the class would be defined as all users or owners of a specific, defective product model. The common harm is the exposure to the same safety risk, and the common legal and factual questions are whether the product was defective and whether Halma is liable for the resulting damage.

Contract law provides another powerful avenue, particularly against Halma’s public sector and large commercial customers. We have evidence suggesting that NHS trusts, for example, have faced costly upgrade cycles tied to Halma’s proprietary systems. This points to a potential breach of contract, not just on explicit terms but on the implied terms of satisfactory quality, fitness for purpose, and reasonable service costs. When a public body is locked into a single supplier due to market dominance, any imposition of unfair terms or failure to provide adequate service is a breach of that relationship. The commonality for a class of claimants, such as a group of NHS trusts or housing associations, would be their subjection to the same unfair contractual terms or the same systemic failure in service across a common product platform, leading to shared financial losses and operational disruptions.

Finally, we must expand our thinking to include investor violations. Halma, as a publicly listed FTSE 100 company, has a duty to its shareholders to accurately disclose the material risks it faces. If our investigation reveals that Halma’s corporate reports and ESG statements have downplayed the significant legal and reputational risks associated with its “stealth consolidation” strategy, its exposure to sanctions compliance failures, or the systemic product liability risks it has accumulated, there could be grounds for an investor class action. The commonality for such a class would be all shareholders who purchased stock during a period where these risks were allegedly misrepresented or omitted, and the common harm would be the financial loss incurred when the true scale of these liabilities becomes public, impacting the share price. This cause of action turns Halma’s own corporate structure against it, targeting its duties to the very capital markets that have funded its aggressive expansion. Each of these causes of action feeds into the overarching narrative that Halma’s pursuit of market power has created a web of liabilities and a significant threat to the public interest, which regulators and courts can no longer afford to ignore.