A Call to Action for Participants in the Spanish Compensation Project
To public administrations, healthcare services, and companies throughout Spain: if your organisation has procured fire safety systems, medical devices, or emergency elevator equipment from subsidiaries of the multinational group Halma plc, you may have been a victim of anti-competitive practices and could be entitled to financial compensation1111. Our investigation reveals that Halma has pursued a strategy of “consolidación silenciosa” or stealth consolidation, systematically acquiring key Spanish technology companies, including the fire alarm panel specialist Advantronic Systems, S.L. 2222 and the former national market leader in elevator emergency telephones, SETCO S.A. (Microkey)3333. This strategy has eliminated independent Spanish competitors and allowed Halma to build dominant market positions while avoiding the scrutiny of Spain’s competition authority, the CNMC4444. This market power may have enabled Halma to impose excessive prices for essential equipment used in Spanish hospitals and public buildings, in potential breach of Article 3 of the Spanish Ley de Defensa de la Competencia5555. If your organisation has been forced to pay inflated prices or has seen its choice of suppliers unlawfully restricted, we urge you to join our collective action to recover these financial losses. By uniting, we can mount a powerful claim for damages and hold Halma accountable for its conduct in the Spanish market. Please contact COCOO for a confidential evaluation of your case and to join our effort to secure compensation.
A Call to Action for Participants in the Spanish Contract Project
We issue an invitation to Spanish public sector bodies, hospital managers, and industrial leaders to participate in our proactive Contract Project. If your organisation is currently bound by long-term contracts for life-critical technology with Halma group companies, or if you are considering new procurement processes in these areas, you may be exposed to significant contractual risks that undermine fair competition and local innovation6666. Our analysis shows that Halma’s market power, strengthened by its acquisition of Spanish firms like Advantronic and Microkey, can lead to vendor lock-in through proprietary ecosystems that are not interoperable with products from other suppliers7777. This strategy stifles competition from other Spanish and European firms and can trap your organisation in expensive and inflexible long-term service and upgrade agreements, ultimately harming Spanish taxpayers and consumers8888. The COCOO Contract Project offers a strategic review of your existing contracts and future tender specifications to identify and challenge potentially unlawful anti-competitive terms. We can provide the expertise to help you draft procurement requirements that mandate open standards, foster a competitive and resilient supply chain, and ensure compliance with Spanish and EU public procurement law9. We invite you to collaborate with us to restore your negotiating power, protect your budgets, and promote a fair and innovative market for essential safety technologies in Spain.
The legal principle underpinning our approach, which is well-established in both Spanish and broader European Union competition law, is the doctrine of the “single economic unit”1111. This doctrine allows regulators and courts to treat a parent company and its wholly-owned subsidiaries as a single undertaking. Consequently, Halma plc, as the ultimate parent company exercising decisive influence, can be held directly liable for any infringements of competition law committed by its subsidiaries that affect the Spanish market2222. This prevents the group from shielding itself behind the separate legal personalities of its many acquired companies.
Our primary defendant remains Halma plc, as it is the architect of the “stealth consolidation” strategy that has been implemented across Europe, including in Spain3. However, for conduct within Spain, we can and should also seek liability directly from the specific Spanish companies that Halma has acquired. The documents you provided identify two key Spanish acquisitions. The first is Advantronic Systems, S.L., a Spanish manufacturer of fire alarm control panels with expertise in wireless technology, which was acquired by Halma in 20244444. As an operating company based in Spain, Advantronic is directly liable for its conduct within the Spanish market post-acquisition. The second, and perhaps more telling, acquisition was that of SETCO S.A., which operates under the brand name Microkey, in 20175. The files note that Microkey was a national market leader in the regulated sector of emergency communication systems for elevators6666. By acquiring Microkey, Halma directly eliminated a significant independent Spanish competitor in a critical safety niche, making Microkey and, by extension, Halma a clear target for any claims arising from a lack of competition or abuse of dominance in that specific Spanish market.
Beyond these Spanish-domiciled subsidiaries, we can also seek liability from other Halma group companies whose products are sold extensively in Spain and whose conduct has a direct effect on Spanish customers and markets. The reports specifically mention that products from Apollo Fire Detectors and Ampac are distributed in Spain, contributing to Halma’s significant share of the Spanish fire detection and alarm market7. Crowcon Detection Instruments supplies its gas detectors to the Spanish petrochemical and industrial sectors8888. In the healthcare sector, devices from SunTech Medical (blood pressure monitors) and the ophthalmic instrument brands Keeler and Volk are supplied to Spanish hospitals and clinics, often through local distributors9999. Any exploitative pricing, exclusionary bundling, or other anti-competitive conduct related to the sale of these products into Spain would create liability for these specific operating companies, as well as for the parent, Halma plc.
The case files for Spain provide additional crucial evidence to support our claims. They highlight that Halma’s acquisitions of companies like Advantronic and Microkey were deliberately structured to be small enough to fall below the mandatory notification thresholds of Spanish competition law, the Ley de Defensa de la Competencia101010101010101010. This law requires notification if a deal results in a market share of 30 percent or more, an exception Halma likely used by arguing the target’s turnover was below the de minimis threshold11111111. This pattern of avoiding scrutiny is a central theme of our case. Furthermore, the documents raise specific concerns about Halma’s ability to leverage its portfolio and achieve a dominant position in narrowly defined Spanish markets, such as ophthalmic lenses, where Spanish clinics would have few, if any, alternative suppliers12121212. This information allows us to present a compelling case to the Spanish competition authority, the CNMC, that Halma’s conduct warrants a full investigation under Spanish law for a potential abuse of a dominant position, with all the legal and financial liabilities that would entail for the entire Halma group.
LICITACIONES EN ESPANA
As your solicitor, I understand your strategic objective perfectly. You are asking me to analyse how we can leverage the Spanish public procurement platforms, such as the Plataforma de Contratación del Sector Público and the ROLECE register, to identify active or upcoming tenders that align with the causes of action we have developed in our case against Halma plc. While I cannot perform a live search of these external websites, I can provide you with a detailed strategic framework for identifying the most promising opportunities and explain how they can be used to advance our core projects. Our goal is not simply to find tenders, but to find strategic battlegrounds where the harms of Halma’s market consolidation are most apparent and where we can introduce pro-competitive solutions.
Our approach on the Plataforma de Contratación del Sector Público should be methodical. We must search for tenders using keywords that correspond directly to the specific product markets where Halma is dominant. In Spanish, this would include terms like “sistemas de detección de incendios,” “paneles de control de alarmas,” “equipos de oftalmología,” “monitores de presión arterial,” and “sistemas de comunicación de emergencia para ascensores.” We should also search directly for tenders that mention Halma’s key brands by name, including Apollo, Advanced, Crowcon, Keeler, SunTech, and most importantly, their Spanish subsidiaries Advantronic and Microkey. This will allow us to pinpoint situations where public bodies may be locked into Halma’s ecosystem.
We should focus our search on identifying three specific types of high-impact tenders. Firstly, we must look for large-scale framework agreements for the maintenance and servicing of existing safety and medical systems in public buildings, particularly hospitals and transportation networks. These long-term contracts are where Halma’s alleged exploitative conduct, through excessive pricing and proprietary upgrade paths, can inflict the most significant financial harm on the public purse. Identifying these tenders before they are awarded gives us a critical window to approach the contracting authority with our findings, warning them of the long-term costs of vendor lock-in and the legal risks of a non-competitive procurement.
Secondly, we must be vigilant for tenders where the technical specifications appear to be unlawfully tailored to favour Halma’s products. For example, a tender for fire alarm systems that requires compatibility only with a specific proprietary protocol used by Halma’s Advanced panels effectively excludes all other competitors. This is not a competitive process; it is a description of a pre-determined outcome. Finding such a tender provides us with direct evidence of a distorted market and gives us grounds to support a legal challenge against the tender itself for being discriminatory and anti-competitive. This not only disrupts Halma’s hold on the market but also positions COCOO as a defender of fair public procurement rules.
Thirdly, we should proactively search for any tenders that explicitly request solutions based on “open standards” or “interoperability.” These public bodies are our natural allies. By identifying them, we can provide our research and analysis to support their pro-competitive stance and help them build a robust case for why an open, competitive tender process leads to greater innovation, lower costs, and enhanced public safety by avoiding the systemic risks of relying on a single dominant supplier.
The other platform you mentioned, the ROLECE register, serves a different but complementary purpose. We can use this official register to identify all the qualified Spanish companies that are Halma’s direct competitors in these specific product categories. This provides us with a target list of potential collaborators. We can approach these Spanish firms, many of whom may have been marginalised by Halma’s market power, and offer to support them in challenging restrictive tenders or in forming consortia to provide competitive, interoperable alternatives. This strategy builds a powerful coalition, turning our public interest case into a tangible commercial and legal challenge supported by Halma’s own domestic rivals. By using these platforms in this strategic manner, we transform our legal case into a proactive intervention, offering public bodies a clear path to escape contractual servitude and restore fair, sustainable competition to these life-critical markets