A Call to Action for Participants in the European Compensation Project
To public authorities, healthcare providers, and corporations across the European Union: if your organisation has procured fire safety, medical diagnostic, or industrial safety equipment from subsidiaries of the UK-based conglomerate Halma plc, you may have been a victim of anti-competitive practices and could be entitled to substantial compensation. Our investigation reveals that Halma has pursued a “stealth consolidation” strategy, systematically acquiring key European technology companies in Portugal, France, Spain, the Netherlands, and Germany, among others1111111111111111111111111111111111111111111111111. This strategy has been designed to accumulate dominant market positions while avoiding the scrutiny of EU merger control2222222222222222. This market dominance, potentially in breach of Article 102 of the TFEU, may have enabled Halma to impose excessive prices for essential goods like ophthalmic devices and fire detection systems, harming public and private budgets across the single market333333333. We are now building a pan-European collective action to recover these financial losses. By joining our Compensation Project, your organisation can unite with others across the EU to build a powerful claim for damages. Collective action is the most effective means to challenge a cross-border conglomerate and secure redress for harm that affects trade between member states. We urge you to contact COCOO for a confidential assessment of your potential claim and to join us in defending the integrity of the European single market.
A Call to Action for Participants in the European Contract Project
We invite public procurement bodies, hospital networks, and industrial leaders throughout the European Union to participate in our proactive Contract Project. If your organisation is bound by or considering long-term contracts for life-critical technologies from Halma group companies such as Apollo, Crowcon, Keeler, or SunTech, you may be exposed to significant contractual and systemic risks that undermine European strategic interests. Our findings show that Halma’s market power can lead to “vendor lock-in” through proprietary systems that lack interoperability, stifling innovation and excluding competitive European suppliers4444. This creates a fragile supply chain and a dangerous dependency on a single, non-EU-based corporate group for the safety of your critical infrastructure5. The risk is not hypothetical; product recalls, such as the one affecting SunTech Medical monitors, demonstrate how a failure at one company can disrupt service delivery across multiple member states simultaneously6666666666666666666666666666666666666666666666666. Our Contract Project offers a strategic review of your current and future procurement agreements to identify and challenge unlawful or unfair terms. We will work with you to develop procurement specifications that mandate open standards, foster a diverse and resilient European supply chain, and comply fully with EU public procurement directives. Join us to future-proof your contracts, restore your bargaining power, and ensure the safety and competitiveness of the European internal market.
HALMA EU CASE
Of course. Based on my comprehensive analysis of the case files you have provided pertaining to the European Union, we can strategically identify the corporate entities within the Halma group from which we could seek liability and outline the additional information that strengthens our case at the EU level.
Our legal approach within the European Union is grounded in two fundamental principles of EU competition law. The first is the “single economic unit” doctrine, which holds that a parent company like Halma plc and the subsidiaries over which it exercises decisive influence are collectively considered a single undertaking1111. This means Halma plc can be held directly liable for infringements committed by any of its European subsidiaries2222. Secondly, the “effects doctrine” establishes that the European Commission has jurisdiction over conduct by companies based outside the EU, such as Halma plc post-Brexit, if their actions have a foreseeable and substantial effect on competition within the EU single market3333. These principles ensure that our legal actions can target the entire group structure, not just isolated entities.
The primary defendant remains Halma plc, the UK-based parent company that orchestrates the group’s global “stealth consolidation” strategy4444. However, we can and should also pursue liability directly from the specific Halma subsidiaries that are domiciled or have a major operational footprint within the European Union. The case files clearly identify several key EU-based companies acquired by Halma that are central to our case. These include G.F.E. (Global Fire Equipment), S.A. in Portugal, a significant fire alarm systems supplier acquired in 2024555555555; Lamidey Noury Medical in France, a manufacturer of surgical equipment also acquired in 2024666666666; Advantronic Systems, S.L. in Spain, a specialist in fire safety panels 777777777; and Netherlocks Safety Systems in the Netherlands, among others8888. These EU-based subsidiaries are directly subject to EU law and can be held liable for any anti-competitive conduct in their respective markets or across the single market.
Furthermore, liability can be sought from other major Halma subsidiaries, even those based outside the EU, due to their significant impact on European markets. Apollo Fire Detectors, though UK-based, is a leading supplier across Europe, and its market share combined with other Halma brands like G.F.E. contributes to a highly concentrated EU market for fire detection9999999999999999. Likewise, Crowcon Detection Instruments is a prominent player in EU industrial safety markets 101010101010101010, while Halma’s “Health Optics” companies, such as Keeler and the US-based Volk, are common suppliers to ophthalmology clinics throughout the EU, allegedly holding a dominant share in certain niche device categories11111111111111111111111111111111. Any exploitative pricing or exclusionary strategies affecting customers in any EU member state can be attributed to these operating companies and, ultimately, to Halma plc.
The new case files significantly bolster our position by demonstrating how this issue cuts across the mandates of multiple European Commission Directorates-General. Our submissions to DG COMP (Competition), DG SANTE (Health), DG GROW (Internal Market), and DG ENER/ENV (Energy/Environment) frame Halma’s conduct not merely as a competition law issue, but as a threat to core EU policy objectives. We can argue that the consolidation in medical devices creates risks for public health and supply chain resilience, a matter for DG SANTE12. The potential for reduced innovation in environmental sensors and gas detectors impacts the EU’s Green Deal and energy security goals, engaging DG ENER and DG ENV. The overall effect on the competitiveness of the single market and the viability of smaller EU-based technology firms is a direct concern for DG GROW. This multi-pronged approach strengthens the public interest argument for a comprehensive investigation by the European Commission. The letter to DG COMP rightly highlights the applicability of Article 102 of the TFEU for abuse of dominance and points to the revived Article 22 referral mechanism as a tool that could have been used to scrutinise Halma’s acquisitions, referencing the Illumina/Grail case as a relevant precedent131313131313131313. Citing the European Commission’s action against Aspen Pharma for excessive pricing of cancer drugs provides a powerful analogy for potential action against Halma in the healthcare sector141414141414141414. This collective body of evidence and legal argument provides a solid foundation for seeking liability from Halma plc and its numerous European and international subsidiaries for their conduct affecting the EU single market
EU TENDERS
As your solicitor, I have reviewed your request to identify relevant ongoing or forthcoming European Union tenders that align with the causes of action and solutions we have developed in our case against Halma plc. The strategic goal of aligning our Unsolicited Proposal with a live tender process is an excellent one, as it provides a concrete focus for our efforts and a direct opportunity to intervene in the market. While my access limitations prevent me from searching the Tenders Electronic Daily platform in real-time to provide you with a list of specific current tenders and their deadlines, I can provide a detailed strategic framework for how your team should conduct this search and what to look for. This will ensure you can effectively identify the most impactful opportunities to advance our case.
Your primary focus should be on the Tenders Electronic Daily, or TED, platform, which is the official source for all high-value public procurement across the European Union. A systematic search of TED is required to uncover the tenders that are most vulnerable to the issues of market dominance and vendor lock-in that we have identified with Halma. Your team should use a combination of precise keywords and Common Procurement Vocabulary codes, or CPV codes, to conduct these searches. Relevant keywords in English would include “fire detection system,” “ophthalmic equipment,” “patient monitoring,” and “gas detector,” but it is crucial to also search in the languages of key EU member states like Germany, France, and the Netherlands. Most importantly, searches should be conducted for Halma’s specific brand names, such as Apollo, Advanced, Crowcon, Keeler, Volk, SunTech, and its EU-based subsidiaries like G.F.E. and Lamidey Noury. Using specific CPV codes, such as 31625200 for fire-alarm systems or 33121600 for ophthalmic instruments, will yield more precise results.
The objective is not merely to find any tender for these products, but to identify specific types of procurement that represent strategic opportunities. You should hunt for large-scale framework agreements for the maintenance and upgrade of critical infrastructure, such as those issued by national health systems or transport authorities. These long-term, high-value contracts are where Halma’s alleged anti-competitive practices can cause the most significant harm by locking public bodies into expensive, proprietary ecosystems for years to come. Identifying these tenders before their submission deadline, which is always specified in the contract notice on TED, provides us with a critical window to intervene.
Furthermore, it is essential to scrutinise the technical specifications of any relevant tender. We must search for language that effectively designs the tender for a Halma-specific solution, for example, by requiring compatibility only with a proprietary software protocol or a specific piece of Halma hardware. Such specifications are direct evidence of a non-competitive, distorted procurement process and may be grounds for a legal challenge to annul the tender itself. The other platforms you identified, such as SIMAP and eCertis, can help us in this regard by providing the standard forms and certification requirements against which we can assess the legality and fairness of a tender’s specifications.
I strongly advise that you also focus your searches on Prior Information Notices, or PINs. These are notices published on TED that signal a public authority’s intention to launch a tender in the near future. Monitoring PINs gives us the invaluable advantage of time, allowing us to prepare our strategy well in advance of the formal tender launch and its associated strict deadlines. This gives us more time to approach the contracting authority with our Unsolicited Proposal, build a coalition of Halma’s competitors, or prepare a formal legal challenge to the proposed specifications before they are finalised.
Regarding direct participation, it is unlikely that COCOO itself would bid on a tender. Instead, our strategy is to use an identified tender as a catalyst for action. We can use it as concrete evidence in our media campaign, showing the public exactly how market dominance leads to non-competitive outcomes in their country. We can present it to a coalition of alternative suppliers and support them in putting together a competitive, interoperable bid. Or, most powerfully, we can use it as the basis for a formal complaint to the public authority and potentially to the European Commission, arguing that the tender is unlawful and must be withdrawn and redrafted to allow for fair and open competition. This approach transforms our legal case into a constructive and proactive intervention to restore competition and protect the public interest in the European single market