PharmaVentures Ltd and its subsidiaries ("PharmaVentures") are committed to ensuring that it, its partners, employees, agents and anyone contracted to it comply with the requirements of the UK Bribery Act 2010. PharmaVentures is committed to conducting its business fairly, honestly and openly, and has a zero-tolerance approach towards bribery and corruption. PharmaVentures has implemented a risk-based approach to identify areas where it may be at risk to bribery and has put in place systems and procedures to reduce and manage this risk. It reserves the right not to deal with other entities that do not make the same commitment. PharmaVentures has adopted and implemented a number of policies and procedures which are intended to prevent PharmaVentures, its partners, staff or agents being involved in bribery. These are reviewed regularly to ensure they remain effective. For further information on PharmaVentures’ bribery risk policies and procedures please contact the Compliance Officer, to whom the CEO has given day-to-day responsibility for ensuring that PharmaVentures’ anti-bribery policies and procedures are adhered to.

Treating Customers Fairly Policy Statement

PharmaVentures, its senior management and staff take their regulatory responsibilities very seriously (including any responsibilities due to Consumers serviced by PharmaVentures under the FCA’s Treating Customers Fairly initiative). It is a policy of PharmaVentures to consistently deliver any relevant TCF Consumer Outcomes due to its clients. Where PharmaVentures services both Consumers and other clients then it may adopt a common practice to treat all fairly, in which case that practice is delivered to meet a TCF requirement in the case of Consumers and as a service standard to our other clients. Any client who feels that they have suffered unfair treatment should address their concerns in writing in the first instance to the Compliance Officer of PharmaVentures Ltd, Steve Waterman.