ANTI BRIBERY AND CORRUPTION POLICY

The UK Bribery Act 2010 (the “Act”) came into force on 1 July 2011. Under the Act, it is a criminal offence to offer or receive a bribe, to bribe a foreign public official or to fail to prevent bribery on Luna Pharma Consulting Ltd.’s behalf.

Our Anti Bribery and Corruption Policy

It is the policy of Luna Pharma Consulting Ltd to conduct all of its business in an honest and ethical manner.

We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships and implementing and enforcing effective systems to counter bribery wherever we operate.

Luna Pharma Consulting Ltd and any persons providing services for or on our behalf (“Staff”) shall not offer or receive any money, securities, goods or any other gifts to or from any individual employed by any of its customers, suppliers or trade partners for the purpose of inducing an undue advantage or other favourable business treatment, contrary to the principles of honesty and integrity.

Luna Pharma Consulting Ltd and its Staff shall not provide any foreign or home public official with any money, security or goods for any improper or illegal purpose.

Luna Pharma Consulting Ltd and its Staff will uphold all laws relevant to countering bribery and corruption, including the Bribery Act 2010, in all jurisdictions in which Luna Pharma Consulting Ltd operates.

Luna Pharma Consulting Ltd will cease trading immediately with any organisation, which engages in or which we have reasonable suspicion that it engages in bribery or other corrupt activity and, if appropriate, will report the matter to the relevant authorities.

Our Gifts and Entertainment Policy

The giving and receiving of gifts and entertainment can build understanding and expand relationships in everyday business life, but it can also cause conflict of interest between personal interests and professional duty.

This policy does not prohibit normal and appropriate hospitality (given and received) to and from third parties.

To avoid any misunderstanding or potential breaches of legislation, Luna Pharma Consulting Ltd is committed to a policy of transparent, proportionate, reasonable and bona fide hospitality and promotional expenditure. 
The acceptance or offer of any gift or entertainment regardless of value, that either makes the recipient feel obliged (or could be construed as a means to make the recipient feel obliged) to start or continue a business relationship, is unacceptable and will be a violation of our policy.

The giving and receiving of promotional items of nominal value or modest entertainment is acceptable where such hospitality is commensurate with the reasonable proportionate norms for the industry in which we operate. We appreciate the co-operation of our trading partners in respect of the above policies.