List of Documents and Questions to Request Under FOI
1. CMA case files on Halma plc or subsidiaries (Apollo, Crowcon, Keeler, SunTech) related to merger reviews or antitrust investigations from 2015–2025, including merger notifications, market studies, or enforcement actions, excluding confidential commercial details.
2. CMA correspondence with Halma or its subsidiaries regarding acquisitions (e.g., G.F.E., Advantronic) or market dominance complaints, redacted for non-exempt information only, from 2015–2025.
3. MHRA safety alerts, recall notices, or investigation reports for Halma’s products (e.g., Crowcon gas detectors 2016, SunTech blood pressure monitors 2024), limited to public safety data.
4. NHS procurement contracts awarded to Halma or subsidiaries (Apollo, Keeler) for fire detection or medical devices from 2015–2025, including contract values and terms, excluding sensitive pricing details.
5. Department of Health and Social Care (DHSC) records of complaints or disputes involving Halma’s medical devices (e.g., Keeler, SunTech) related to overpricing or exclusivity, from 2015–2025, redacted for non-exempt data.
6. Export Control Joint Unit (ECJU) records of investigations or enforcement actions against Halma or Crowcon for 2018 Iran sanctions violations, limited to non-confidential outcomes.
7. Companies House filings for Halma plc (CRN: 00040932) and subsidiaries (e.g., Apollo CRN: 01483439, Crowcon CRN: 00982878), including PSC registers and annual returns from 2015–2025, to verify ownership and compliance.
8. Home Office records of fire safety compliance investigations involving Apollo Fire Detectors’ products in public buildings, from 2015–2025, excluding third-party commercial data.
9. Department for Business and Trade (DBT) correspondence on Halma’s export activities to Iran in 2018, focusing on public policy implications, redacted for non-exempt data.
10. Cabinet Office records of lobbying activities by Halma or its representatives, as reported in the Register of Consultant Lobbyists, from 2015–2025, limited to public interest disclosures.
**Questions to Ask**
1. Has the CMA investigated Halma plc or its subsidiaries for potential breaches of Chapter II of the Competition Act 1998, particularly excessive pricing or abuse of dominance, since 2015? If so, what were the outcomes?
2. What merger notifications or inquiries has the CMA received regarding Halma’s acquisitions (e.g., G.F.E., Advantronic) since 2015, and what public findings were made?
3. Has the MHRA issued safety alerts or conducted investigations into Halma’s products (e.g., Crowcon gas detectors, SunTech medical devices) since 2015, and what public safety data is available?
4. What is the total value of NHS contracts awarded to Halma or its subsidiaries for fire detection or medical devices since 2015, and are there public records of exclusivity clauses?
5. Has the DHSC received complaints about Halma’s medical devices (e.g., Keeler, SunTech) related to pricing or contract terms since 2015, and what public actions were taken?
6. Did the ECJU investigate Halma or Crowcon for export control violations related to Iran in 2018, and what public enforcement actions were recorded?
7. Are there any public records of Halma’s failure to comply with PSC reporting requirements under the Companies Act 2006 since 2015?
8. Has the Home Office identified non-compliance with fire safety regulations involving Apollo Fire Detectors’ products in public buildings since 2015?
9. Has the DBT corresponded with Halma regarding its export activities to Iran in 2018, and what public policy implications were noted?
10. Are there public records of lobbying by Halma or its representatives with UK government departments since 2015, as held by the Cabinet Office?
**FOIA Compliance Considerations**:
– **Public Authorities**: Requests target CMA, MHRA, DHSC, ECJU, Companies House, Home Office, DBT, and Cabinet Office, all subject to FOIA.
– **Exemptions**: I’ve avoided requests for commercially sensitive data (s.43), personal data (s.40), or active investigation details (s.30) by focusing on public outcomes, redacted documents, or aggregated data.
– **Public Interest**: Requests emphasize public safety (recalls), market fairness (competition), and transparency (lobbying, exports), which override exemptions under FOIA s.2.
– **Limitations**: Authorities may redact sensitive data or deny requests if deemed vexatious (s.14) or exceeding cost limits (£600, s.12). Requests are specific to stay within bounds.
– **EU Law**: The letter includes a forwarding clause per EU transparency principles (e.g., Regulation 1049/2001), ensuring misdirected requests are rerouted.
### Draft Freedom of Information Request Letter
Oscar Moya
[Your Address]
[City, Postal Code]
[Email: contact@cocoo.uk]
[Date: July 18, 2025]
Freedom of Information Officer
Competition and Markets Authority
The Cabot, 25 Cabot Square
London, E14 4QZ
Dear Sir/Madam,
Subject: Freedom of Information Request
I am writing to request information under the Freedom of Information Act 2000. If this request has not reached the appropriate department, please forward it to the relevant authority within your organization, as required by EU transparency obligations (Regulation 1049/2001).
I seek the following documents and information held by the Competition and Markets Authority (CMA), Medicines and Healthcare products Regulatory Agency (MHRA), Department of Health and Social Care (DHSC), Export Control Joint Unit (ECJU), Companies House, Home Office, Department for Business and Trade (DBT), and Cabinet Office, relating to Halma plc and its subsidiaries (e.g., Apollo Fire Detectors, Crowcon Detection Instruments, Keeler Ltd, SunTech Medical):
1. CMA case files on Halma plc or subsidiaries concerning merger reviews or antitrust investigations from 2015–2025, including non-confidential merger notifications or market studies.
2. CMA correspondence with Halma regarding acquisitions or market dominance complaints from 2015–2025, redacted for non-exempt information.
3. MHRA safety alerts or investigation reports for Halma’s products (e.g., Crowcon gas detectors 2016, SunTech blood pressure monitors 2024), limited to public safety data.
4. NHS procurement contracts awarded to Halma or subsidiaries for fire detection or medical devices from 2015–2025, including contract values, excluding sensitive pricing.
5. DHSC records of complaints involving Halma’s medical devices related to pricing or exclusivity from 2015–2025, redacted for non-exempt data.
6. ECJU records of investigations into Halma or Crowcon for 2018 Iran sanctions violations, limited to non-confidential outcomes.
7. Companies House filings for Halma plc (CRN: 00040932) and subsidiaries (e.g., Apollo CRN: 01483439), including PSC registers and annual returns from 2015–2025.
8. Home Office records of fire safety compliance investigations involving Apollo’s products in public buildings from 2015–2025, excluding third-party commercial data.
9. DBT correspondence on Halma’s 2018 Iran export activities, focusing on public policy implications, redacted for non-exempt data.
10. Cabinet Office records of lobbying by Halma or its representatives from 2015–2025, limited to public interest disclosures.
Additionally, I request answers to the following questions:
1. Has the CMA investigated Halma for breaches of Chapter II of the Competition Act 1998 since 2015, and what were the outcomes?
2. What merger inquiries has the CMA received regarding Halma’s acquisitions since 2015, and what public findings were made?
3. Has the MHRA issued safety alerts or investigated Halma’s products since 2015, and what public safety data is available?
4. What is the total value of NHS contracts awarded to Halma since 2015, and are there public records of exclusivity clauses?
5. Has the DHSC received complaints about Halma’s medical devices since 2015, and what public actions were taken?
6. Did the ECJU investigate Halma for 2018 Iran export violations, and what public actions were recorded?
7. Are there public records of Halma’s PSC reporting non-compliance since 2015?
8. Has the Home Office identified non-compliance with fire safety regulations involving Apollo’s products since 2015?
9. Has the DBT corresponded with Halma on 2018 Iran exports, and what public policy implications were noted?
10. Are there public records of Halma’s lobbying with government departments since 2015?
Please provide the information in electronic format where possible, within the 20-working-day statutory period. If any part of this request is exempt, please provide the non-exempt portions and specify the exemption applied. If clarification is needed, contact me at contact@cocoo.uk.
Thank you for your assistance.
Yours sincerely,
Oscar Moya
—
This letter and list adhere to FOIA requirements, targeting disclosable information to advance your case against Halma plc while respecting exemptions and EU forwarding obligations. If you need further refinements, please specify.[](https://find-and-update.company-information.service.gov.uk/company/00040932)
New Batch of Search Links for Deeper Analysis
1. **https://www.justice.gov/atr/antitrust-case-filings**
– **Purpose**: The U.S. Department of Justice (DOJ) Antitrust Division database provides access to antitrust case filings and enforcement actions, critical for investigating potential competition law violations by Halma’s US subsidiaries.
– **Search Strategy**: Search for “Halma plc,” “Volk Optical,” or “SunTech Medical” in case filings. Use keywords like “market dominance” or “anti-competitive practices” and filter by date (e.g., 2015–2025).
– **Relevance**: This resource can uncover US antitrust investigations or settlements, supporting claims of abuse of dominance or anti-competitive conduct in markets like medical devices.
2. **https://www.competitionpolicyinternational.com/**
– **Purpose**: Competition Policy International (CPI) provides analysis, news, and reports on global competition law and policy, offering insights into Halma’s competitive practices across jurisdictions.
– **Search Strategy**: Search for “Halma plc competition” or “safety equipment market dominance.” Use filters for articles or case studies related to the UK, EU, or US.
– **Relevance**: CPI can provide expert commentary or precedent cases (e.g., excessive pricing in safety equipment), strengthening competition law arguments.
3. **https://www.fda.gov/medical-devices/device-advisories-and-recalls**
– **Purpose**: The FDA’s database tracks medical device recalls and safety advisories in the US, relevant for Halma subsidiaries like SunTech Medical or Volk Optical.
– **Search Strategy**: Search for “SunTech Medical blood pressure” or “Volk Optical recall.” Filter by recall date (e.g., 2024) and device category (e.g., ophthalmic or cardiovascular).
– **Relevance**: This can provide evidence of product defects or regulatory actions, bolstering product liability claims against Halma’s US operations.
4. **https://www.mhra.gov.uk/**
– **Purpose**: The UK’s Medicines and Healthcare products Regulatory Agency (MHRA) database offers information on medical device safety alerts and recalls, crucial for Halma’s UK subsidiaries like Keeler Ltd.
– **Search Strategy**: Search for “Keeler Ltd” or “ophthalmic device safety.” Use filters for medical device alerts and date range (e.g., 2015–2025).
– **Relevance**: This resource can reveal UK-specific product safety issues, supporting tort claims or compliance violations.
5. **https://www.bloomberg.com/**
– **Purpose**: Bloomberg provides financial news, market data, and company profiles, offering insights into Halma’s acquisitions, market position, and economic influence.
– **Search Strategy**: Search for “Halma plc acquisition” or “safety equipment market share.” Use filters for news or company analysis sections.
– **Relevance**: This can quantify Halma’s market dominance (e.g., through acquisitions like Apollo) and support economic duress or stealth consolidation arguments.
6. **https://www.ft.com/**
– **Purpose**: The Financial Times (FT) offers in-depth reporting on corporate strategies, legal disputes, and market trends, relevant to Halma’s global operations.
– **Search Strategy**: Search for “Halma plc competition law” or “Crowcon sanctions Iran.” Filter by date (e.g., 2018 for sanctions) and section (e.g., Companies or Law).
– **Relevance**: FT articles can provide investigative details on Halma’s conduct, such as the 2018 Iran sanctions issue, enhancing compliance and competition claims.
7. **https://www.lexisnexis.com/**
– **Purpose**: LexisNexis is a premium legal research database with case law, statutes, and news across jurisdictions (UK, EU, US), ideal for comprehensive legal analysis of Halma’s activities.
– **Search Strategy**: Use Boolean searches like “Halma plc AND (competition OR product liability)” or “Crowcon AND sanctions.” Filter by jurisdiction and date (2015–2025).
– **Relevance**: This can uncover detailed legal precedents or litigation history, supporting all key areas of the case (requires subscription).
8. **https://www.reuters.com/**
– **Purpose**: Reuters provides global news coverage on business, legal, and regulatory developments, useful for tracking Halma’s market conduct and compliance issues.
– **Search Strategy**: Search for “Halma plc product recall” or “Halma sanctions violation.” Filter by date (e.g., 2016–2024) and topic (e.g., Legal or Business).
– **Relevance**: Reuters can offer timely reports on recalls (e.g., Crowcon 2016) or sanctions, supporting factual claims across jurisdictions.
9. **https://www.iso.org/standards.html**
– **Purpose**: The International Organization for Standardization (ISO) database lists standards for safety equipment and medical devices, relevant to Halma’s product compliance.
– **Search Strategy**: Search for standards like “ISO 13485” (medical devices) or “ISO 9001” (quality management) with keywords like “fire detection” or “ophthalmic.”
– **Relevance**: This can assess whether Halma’s products meet global standards, supporting or refuting product liability and compliance claims.
10. **https://www.trade.gov/export-compliance**
– **Purpose**: The U.S. Department of Commerce’s export compliance site provides resources on export controls and sanctions, critical for Halma’s 2018 Iran-related issues.
– **Search Strategy**: Search for “Iran sanctions safety equipment” or “Crowcon Detection Instruments export.” Review export control lists and enforcement actions.
– **Relevance**: This can confirm US export control violations, strengthening sanctions-related arguments.
—
### Recommendations for Use
– **Prioritize**: Begin with **justice.gov/atr** and **LexisNexis** for legal depth on competition law, followed by **FDA** and **MHRA** for product liability evidence.
– **Execution**: Use advanced search features (e.g., Boolean operators, date filters) to refine results. Cross-check findings (e.g., sanctions data from trade.gov with news from Reuters).
– **Limitations**: Some resources (e.g., LexisNexis, Bloomberg) require subscriptions. For inaccessible data, consider public records requests or legal discovery.
# Search Links for Halma plc Case Investigation
## 1. U.S. DOJ Antitrust Case Filings
– **URL**: https://www.justice.gov/atr/antitrust-case-filings
– **Purpose**: Access antitrust case filings and enforcement actions in the US.
– **Search Strategy**: Search “Halma plc,” “Volk Optical,” or “SunTech Medical” with keywords like “market dominance.” Filter by date (2015–2025).
– **Relevance**: Uncovers US antitrust issues, supporting competition law claims.
## 2. Competition Policy International (CPI)
– **URL**: https://www.competitionpolicyinternational.com/
– **Purpose**: Provides global competition law analysis and reports.
– **Search Strategy**: Search “Halma plc competition” or “safety equipment market dominance.” Filter by region (UK, EU, US).
– **Relevance**: Offers expert insights into Halma’s competitive practices.
## 3. FDA Medical Device Recalls
– **URL**: https://www.fda.gov/medical-devices/device-advisories-and-recalls
– **Purpose**: Tracks US medical device recalls and safety advisories.
– **Search Strategy**: Search “SunTech Medical blood pressure” or “Volk Optical recall.” Filter by 2024 and device type.
– **Relevance**: Evidence for product liability claims in the US.
## 4. MHRA (UK)
– **URL**: https://www.mhra.gov.uk/
– **Purpose**: Provides UK medical device safety alerts and recalls.
– **Search Strategy**: Search “Keeler Ltd” or “ophthalmic device safety.” Filter by alerts (2015–2025).
– **Relevance**: Supports UK product liability and compliance analysis.
## 5. Bloomberg
– **URL**: https://www.bloomberg.com/
– **Purpose**: Offers financial news and company data on Halma.
– **Search Strategy**: Search “Halma plc acquisition” or “safety equipment market share.” Filter by news or analysis.
– **Relevance**: Quantifies market dominance and economic duress.
## 6. Financial Times (FT)
– **URL**: https://www.ft.com/
– **Purpose**: Reports on corporate strategies and legal disputes.
– **Search Strategy**: Search “Halma plc competition law” or “Crowcon sanctions Iran.” Filter by date (e.g., 2018).
– **Relevance**: Details sanctions or competition issues.
## 7. LexisNexis
– **URL**: https://www.lexisnexis.com/
– **Purpose**: Comprehensive legal research across jurisdictions.
– **Search Strategy**: Use “Halma plc AND (competition OR product liability).” Filter by UK, EU, US (2015–2025).
– **Relevance**: Uncovers legal precedents for all case areas (subscription required).
## 8. Reuters
– **URL**: https://www.reuters.com/
– **Purpose**: Global news on business and regulatory developments.
– **Search Strategy**: Search “Halma plc product recall” or “Halma sanctions.” Filter by date (2016–2024).
– **Relevance**: Timely reports on recalls or sanctions.
## 9. ISO Standards
– **URL**: https://www.iso.org/standards.html
– **Purpose**: Lists standards for safety equipment and medical devices.
– **Search Strategy**: Search “ISO 13485” or “ISO 9001” with “fire detection.”
– **Relevance**: Assesses Halma’s product compliance.
## 10. U.S. Export Compliance
– **URL**: https://www.trade.gov/export-compliance
– **Purpose**: Resources on US export controls and sanctions.
– **Search Strategy**: Search “Iran sanctions safety equipment” or “Crowcon export.”
– **Relevance**: Confirms sanctions violations.
– **Relevance**: Strengthens sanctions-related claims.
These resources will enhance the evidence base for the case, covering legal precedents, product safety data, market analysis, and compliance records. Use them strategically to build a compelling argument across all key areas of investigation.
SELFQUESTIONS – PROCUREMENT
As your solicitor, I will now outline the likely answers to the strategic questions we have designed for procurement contractors and public bodies, and detail the range of solutions we can propose in response. This exercise is critical for anticipating their positions and steering the conversation towards the inevitable conclusion: that engaging COCOO is the most viable and effective way to resolve the significant risks they face.
When we begin with our foundational questions about their current procurement frameworks, the answers will be predictable yet revealing. A procurement manager at an NHS Trust or a local authority will describe a process that is, on the surface, compliant and professional. They will confirm that key contracts for fire safety and medical monitoring are indeed held by Halma subsidiaries like Apollo, Advanced, or Keeler. They will state that their evaluation criteria include reliability and technical compliance, but when pressed on criteria such as “long-term supplier diversity,” their answers will become vague. They will confirm that service and maintenance contracts are often long-term. This initial exchange is not confrontational; it simply establishes the facts of their current dependency. At this point, the most viable solution we can introduce is our offer of an independent “Market Health and Supplier Risk Assessment.” It is a non-threatening first step that allows them to acknowledge the situation without admitting fault, positioning our Unsolicited Proposal as a constructive offer of assistance.
As we pivot to our more probing questions about risk and resilience, we will expose a critical capability gap. When we ask if their risk register quantifies the impact of a systemic failure from a dominant supplier, the answer, in almost all cases, will be no. These bodies are not equipped to analyse complex market structures; they manage operational and financial risks in a more direct sense. They will not have calculated the total cost of ownership of a proprietary ecosystem because they have never been challenged to do so. Our questions will force this realisation upon them. The most viable solution we must then present is a concrete offer to conduct this analysis for them. We will propose, as part of our project, to deliver a “Total Cost of Ownership and Systemic Risk Report,” using our evidence from the SunTech and Crowcon recalls to demonstrate that this is a tangible threat, not a theoretical one. We are the only party who can offer this service, as we have already undertaken the foundational research into Halma’s specific market conduct.
This leads naturally to the strategic questions on competition and innovation. The procurement officials will likely concede that they have seen a decline in the number of bidders for specialised tenders over the years. They will likely admit, if indirectly, that their technical specifications often default to the incumbent supplier’s proprietary standards out of perceived necessity, without fully appreciating the anti-competitive consequences. When we ask if they are concerned about innovation stagnation, we are tapping into a genuine but often unarticulated anxiety. Here, the most viable solution is to offer a practical remedy. As a key deliverable of our proposed project, we will provide them with expertly drafted, alternative technical specifications for their next major tender. These specifications will mandate open standards and interoperability, and will break down large contracts into smaller lots. This is a powerful, constructive solution that empowers them to single-handedly restore competition and foster innovation in their supply chain.
Having led them through this logical progression, their answer to our final set of questions becomes a foregone conclusion. When we ask what internal expertise they have to assess supplier concentration risk, they will confirm they have none. And when we ask if a confidential, independent report that maps these risks and provides a strategic roadmap would be a valuable tool for their leadership, the answer will be an emphatic yes. They will now see our Unsolicited Proposal not as an intrusive complaint, but as the necessary solution to a critical vulnerability they have just discovered within their own organisation. The only viable solution at this point is for them to engage COCOO to deliver the very project we have designed. Our questions will have successfully transformed them from passive participants in a broken market into active clients seeking a remedy that only we are positioned to provide.
SELFQUESTIONS – COMPENSATION
As your solicitor, I will now address the strategic questions we previously formulated, providing answers based on our comprehensive investigation into the Halma case. This exercise will clarify the strength of our positions and define the most viable solutions, both for success in a potential court battle and for securing COCOO’s nomination as the official mediator between the parties.
First, let us address the adversarial questions designed to strengthen our hand in litigation. When we ask whether Halma’s board ever formally assessed the cumulative competition law risk of its acquisition strategy, the most probable answer based on the available evidence is that they did not, or if they did, the assessment was fundamentally flawed. The sheer consistency of their sub-threshold acquisitions over more than a decade points to a deliberate corporate strategy, not a series of unrelated events. For a board of a FTSE 100 company to overlook such a foreseeable regulatory risk would represent a serious failure of corporate governance. The most viable solution for us is to use this powerful inference of wilful blindness or negligence to persuade regulators that Halma’s conduct warrants a deeper investigation with a view to imposing more significant penalties, as it speaks to the company’s culture of compliance.
Regarding the question of whether product quality and safety degraded post-acquisition, our answer is that the evidence points towards a significant increase in systemic risk. While Halma will undoubtedly portray the product recalls and safety notices for its SunTech and Crowcon subsidiaries as isolated incidents, we will frame them as inevitable symptoms of a consolidated market. Our most viable solution is to launch a targeted evidence-gathering campaign, reaching out to the classes of victims we have identified, such as NHS engineers and industrial safety officers, to move from individual incidents to a documented pattern of declining service, rising faults, and concerns about quality. This will form the basis of a powerful collective tort action, where the concentrated risk itself is the core of the claim.
When we question what risk assessments public bodies conducted on supplier concentration before awarding contracts to Halma, the almost certain answer is that they performed none. Their procurement processes are typically focused on satisfying the technical requirements of an individual tender at the lowest price, not on analysing long-term market health or supply chain resilience. This failing is their key vulnerability. The most viable solution is not to immediately threaten them with litigation, but to leverage this failure. We will present these public bodies with our own expert analysis, framing our Unsolicited Proposal as a solution to a critical risk they have overlooked. This compels them to support our cause, as we are providing them with the justification and the means to extricate themselves from a dangerous dependency.
Finally, on the question of whether we can quantify the financial harm from excessive pricing, the answer is an unequivocal yes. Our analysis of public NHS procurement data already indicates significant price inflation for Halma’s products that outstrips market averages. The most viable solution is to have our economic experts build a robust “but-for” model, calculating the overcharge on key products. This detailed quantification of damages will be a crucial weapon, first to convince regulators of the tangible harm, and subsequently to form the unassailable core of a follow-on damages claim.
Now, let us turn to the second set of questions, those designed to secure our role as mediator by making all parties see the necessity of a COCOO-facilitated resolution. When we ask Halma how a simple financial settlement can solve its multi-front crisis, and ask the victims how individual claims can solve the underlying market failure, the only logical answer is that they cannot. These questions are designed to force all parties to recognise that their individual interests are inextricably linked within a complex system that is failing all of them. This realisation is the gateway to a collective solution.
When we rhetorically ask which other entity possesses the comprehensive, multi-jurisdictional evidence base required to understand this dispute, we are leading them to the only possible conclusion: only COCOO. This question establishes our unique value proposition. We are not a conventional mediator who is ignorant of the facts; our expertise and deep knowledge are precisely what makes us the only party capable of facilitating an efficient and effective resolution. We are not just neutral; we are uniquely informed.
And when we ask the final, pivotal question – whether it is more rational to engage in a structured dialogue to find a sustainable solution, rather than litigating for a decade – we are reframing the entire conflict. We are moving the parties from a zero-sum battle over past grievances to a collaborative effort to build a better future. The most viable solution that we will guide them towards through this process is a comprehensive, binding settlement agreement. This agreement will have two core components: a compensation fund to provide redress for past financial harms, and a set of forward-looking, non-negotiable commitments from Halma. These will include undertakings to guarantee full interoperability of their systems, to unbundle their products and services, and to adhere to a fair and transparent pricing model, all overseen by an independent monitor. This is the ultimate objective of our case: a permanent solution that restores competition and ensures the long-term safety and sustainability of these vital markets.
MEDIATION
As your solicitor, I have analysed the new materials you have provided on mediation, alternative dispute resolution, and settlement processes. This marks a pivotal and sophisticated evolution in our strategy. Having successfully established the profound and multi-faceted legal risk facing Halma plc, we can now pivot from our role as the primary antagonist to that of the indispensable architect of a comprehensive solution. We will redraft our Unsolicited Proposal and strategic steps, moving away from a procurement-focused approach towards a bold proposal for a COCOO-facilitated, multi-party mediation. This positions us at the centre of the resolution, leveraging our unique knowledge to achieve a faster and more holistic outcome than decades of fragmented litigation.
Our new Unsolicited Proposal will no longer be a pitch for a small investigative contract; it will be a formal invitation to all key parties to enter into a structured settlement dialogue, facilitated by COCOO. This proposal will be directed not only to Halma’s General Counsel and board but also to the legal leadership of the primary victims we have identified: major NHS Trusts, key public authorities responsible for housing and infrastructure, and representative bodies for the competitor firms harmed by Halma’s market conduct. The problem we now propose to solve is not just Halma’s dominance, but the reality of a complex, multi-jurisdictional dispute that, if left to the courts, will result in enormous cost, uncertainty, and years of damaging conflict for every single party involved.
The core of this new proposal is our re-framing of COCOO’s role. We will state clearly that COCOO is prepared to act as the facilitator of this structured dialogue. We must address the question of neutrality head-on. Our proposal will state that COCOO’s unique qualification to mediate stems not from a lack of prior analysis, but from our unparalleled, objective understanding of the entire interconnected system of harm. We are the only entity that has mapped the complex interplay between the competition law violations, the contractual lock-ins, the product liability risks, and the public safety consequences. We will commit to facilitating a confidential, non-binding process based on our evidence, with the sole objective of architecting a comprehensive and sustainable settlement that is acceptable to all parties and serves the public interest.
The steps for this COCOO-led mediation process will be clear and deliberate. The first step is the formal invitation, where we call on Halma and a core group of representative claimants to agree in principle to participate, emphasising the efficiency and confidentiality of this process compared to public litigation. The second step involves intensive pre-mediation caucuses. Our team will meet privately and confidentially with Halma’s legal team to walk them through the full, unvarnished scope of their legal and financial exposure across all fronts, making the case that a negotiated settlement is their most rational path forward. In parallel, we will caucus with the claimant group to consolidate their various demands for compensation and contractual remedies into a single, coherent set of objectives.
The third step is to convene the joint mediation session itself. As the facilitator, we will set a structured agenda focused on finding pragmatic solutions, not re-litigating the past. The discussion will centre on two main pillars: first, addressing the financial harm through the creation of a compensation fund for affected parties; and second, agreeing on forward-looking remedies to restore fair competition. This will involve negotiating Halma’s firm commitment to specific behavioural changes, such as guaranteeing interoperability for its systems, unbundling its products from exclusive service contracts, and adhering to fair, reasonable, and non-discriminatory terms for future dealings. The final step, should an agreement be reached, will be for COCOO to leverage its unique expertise to assist all parties in drafting a detailed and legally binding multi-party settlement agreement. This document will be the ultimate prize of our campaign: a comprehensive resolution that provides redress for past harms and establishes a new, sustainable, and competitive framework for these life-critical markets, all achieved through our strategic intervention.