PharmaVentures Ltd and its subsidiaries (the “Firm”) 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. The Firm is committed to conducting its business fairly, honestly and openly, and has a zero- tolerance approach towards bribery and corruption. The Firm 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. The Firm has adopted and implemented a number of policies and procedures which are intended to prevent the Firm, its partners, staff or agents being involved in bribery. These are reviewed regularly to ensure they remain effective.   For further information on the Firm’s bribery risk policies and procedures please contact the Compliance Officer, to whom the partners have given day-to-day responsibility for ensuring that the Firm’s anti-bribery policies and procedures are adhered to.

Treating Customers Fairly Policy Statement

The Firm, its senior management and staff take their regulatory responsibilities very seriously (including any responsibilities due to Consumers serviced by the Firm under the FCA’s Treating Customers Fairly initiative). It is a policy of the Firm to consistently deliver any relevant TCF Consumer Outcomes due to the Firm’s clients. Where the Firm 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