In my experience subsidiaries who are a legal entity in their own right have had their own individual H&S Policy. Forgetting the legal perspective for a moment, would you have exactly the same policies and procedures for all your companies - no you would not, they need to be relevant to the industry. So why have one H&S Policy for all?

We have a similar if not exactly the same situation. We are a parent organization with several subsidiaries. When I started here I rewrote the policy so it was fit for purpose for the parent. We then agreed the statement of intent with all subsidiaries and that is then shared across the whole group. The responsibilities section is subsidiary specific as obviously each one has its own structure, some aspects are shared. The arrangements section is more site specific which works for us as all activities on each site are similar irrespective of which organization is carrying them out. The key aspect for me is that anyone in any part of any of the subsidiaries can know which policy is theirs and how they fit into it. To a large extent its up to the board of each of your companies as to who they square this all off, as long as the policy/policies cover their activities. Our parent board demands that all subsidiaries fulfill their duties and can prove it. I have had numerous conversations internally as to how we manage this situation and this is what works for us. I guess its different depending on the organization.

You are conflating policies and procedures. I agree companies will have different procedures, but I disagree that this necessarily requires they have different H&S policy. If the companies are operating in the same industry, within the same legal jurisdiction, with a common board of directors (which seems to be the case here), why would they not have the same policy? What would be different from one company to the next? Is one going to have a policy of complying with all statute and another not bother with that? Our policy is (roughly): 1: comply with statute 2: safeguard health, safety and welfare of all employees 3: organise affairs to comply with the policy 4: ensure competent people in post and provide training 5: review policy periodically 6: board are committed 7: neglect of policy treated as serious breach - disciplinary Now, if we had a sister company in the same industry in the UK with the same (or even just overlapping) board, I would be astonished if the sister company said anything different to that.

In that situation, I think it's mainly a matter of semantics as to whether the individual company doesn't have a safety policy because the group has a policy, or whether all the companies in the group have the same policy. In the latter case, they meet the legal requirement, I think. That probably simply means that the one policy should be recorded as ' the policy of each company in the group', rather than 'the policy of the parent of the group'. I note the OP refers to the policy naming each company, so I suspect it's closer to the former (and therefore legal, in my non-lawyer view). That is, each company needs a H&S policy, but it can be the same policy, and even the same piece of paper, if you want it framed on the wall somewhere.