POLICIES

Privacy and Cookie Policy

 

Introduction

 

Luna Pharma Consulting Ltd. (“we or us”) is committed to protecting and respecting your privacy. Our objective is to comply with General Data Protection Regulation (the “GDPR”), making sure the data we collect is minimal and kept safe at all times.

We act as the data controller.

This policy sets out the basis on which the personal data we are collecting from you will be processed by us. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.

What does this Policy cover?

 

This Privacy Policy applies only to your use of our website.

Links to other websites are provided for the convenience of users. If you follow a link to any of these websites, please note that they have their own privacy policies and that Luna Pharma does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

What are your rights?

 

Under the GDPR, you have the following rights, which we will always work to uphold:

  • The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in below.

  • The right to access the personal data we hold about you by contacting us using the details below.

  • The right to have your personal data rectified if any of your personal data held us is inaccurate or incomplete. Please contact us using the details in the “contact us” section below to find out more.

  • The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in “contact us” section below to find out more.

  • The right to restrict (i.e. prevent) the processing of your personal data.

  • The right to object to us using your personal data for a particular purpose or purposes.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in the “contact us” section below.

What Personal Data do we collect?

 

If you contact us via email, we may collect your name, email address and any other information which you choose to share with us.

Collection of the data is purely for our internal usage and we do not share it with other parties.

 

In addition, we may gather anonymous information about you automatically through your use of the Site, e.g., your IP address and how you navigate our Site. See also, the Section below on Cookies and Other Tools.

How do we use your Personal Data?

 

If we do collect any personal data, it will be processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the GDPR at all times.

We only collect personal data If you contact us and we obtain your personal details from your email, we may use them to respond to your email.

Any and all emails containing your personal data will be deleted no later 12 months after receipt.

You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it.

We will not share any of your data with any third parties for any purposes other than storage on an email server in the European Economic Area (the “EEA”).

How and where do we store your data?

 

We will only store your personal data within the European Economic Area (the “EEA”) plus Turkey where our Liaison office is based. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.

Personal data security is essential to us and to protect personal data, we take the following measures:

Ensuring that we have adequate site security including relevant SSL Certificates for the site.

Mandatory Cookie acceptance choice for visitors to the website

If you email us, we will store your details in a secure server environment.

How can you access your personal data?

If you want to know what personal data we store about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in the ‘contact us’ section of this page.

We will respond to your subject access request within 2 weeks and, in any case, not more than one month of receiving it.  Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

Cookies and other tools

 

We collect information about you by using cookies, tracking pixels and other technologies (collectively, “Tools”). We use this information to better understand, customize and improve user experience with our websites, services and offerings as well as to manage our advertising. For example, we use web analytics services that leverage these Tools to help us to understand how visitors engage with and navigate our Site, e.g., how and when pages in a site are visited and by how many visitors. We are also able to offer our visitors a more customized, relevant experience on our sites using these Tools by delivering content and functionality based on your preferences and interests.

We may use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Site and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources.

 

We use cookies to help improve our website and make your browsing experience more useful, more relevant and tailored to you. In order to comply with recent legislation and in the interests of transparency, we have updated our privacy policy to give you clearer information on the way we use technology such as cookies and how they affect your privacy.

How do I opt out of Cookies?

 

To make full use of the features on our site you will need to accept cookies, as we can only provide you with certain personalised features of this website by using them.

If you’d prefer to restrict, block or delete cookies from our websites or any other website, you can use your browser to do this though your experience of using the site may be significantly impaired should you do so (although, if you choose to restrict, block or delete third party cookies we do not envisage that this will significantly impair the functionality of our website).

Changes to our Privacy Policy

 

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business or website in a way that affects personal data protection.

Any changes will be immediately posted on our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

Contact us

 

Luna Pharma Consulting Ltd. is the company responsible for collection, use and disclosure of your personal data under this Privacy.

If you have questions about this Privacy Policy, or if you would like to request the exercise of any individual rights, please contact us by emailing the Privacy Data Controller, or write to the following address:

Privacy Data Controller

Luna Pharma Consulting Ltd

25 Eccleston Place

London

SW1W 9NF

info@lunapharmaconsulting.com

Anti-Corruption and Bribery Policy 
 
Preamble: 
A: The name of this organization is Luna Pharma Consulting Limited (hereinafter referred to as ‘Luna’ or ‘The Company’) of The House High Street Brenchley, Kent, TN12 7NQ (hereinafter referred to as ‘The Registered Address’) (UK Registration Number: 10241868). The shortened name may also be an acronym, and if an acronym is used, this Policy Document may - after stating the full name of the organization - show also from timeto-time the shortened name ‘Luna’ or its acronym ‘’LPC’ in all publicity materials and correspondence. 
 
B: The officers of Luna Pharma Consulting Limited shall make up the Executive Board of Luna Pharma Consulting Limited (hereafter referred to as the ‘Board’). 
 
C: The Director of Luna Pharma Consulting Limited shall be Ms. Gulce BELGIN (hereinafter referred to as ‘The Director’). 
 
D: The Laws which governs this policy document of Luna Pharma Consulting Limited is The Bribery Act 2010 (hereinafter referred to as ‘The Act’). 
 
 
1. INTRODUCTION 
1.1 It is the Company’s policy to conduct its business in an honest and ethical manner. 
The Company takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships wherever the Company operates. 
1.2 The Company will uphold all laws relevant to countering bribery and corruption including the Bribery Act 2010 (‘the Act’), in respect of its conduct both at home and abroad. 
1.3 The purpose of this policy is: 
1.3.1 To set out the responsibilities of the Company, and of those working for it, in observing and upholding our position on bribery and corruption; and  
1.3.2 To provide information and guidance to those working for the Company on how to recognise and deal with bribery and corruption issues. 
1.4 Bribery and corruption are punishable for individuals by up to ten years' imprisonment and if the Company is found to have taken part in corruption it could face an unlimited fine, be excluded from tendering for public contracts and face damage to its reputation. The Company therefore takes its legal responsibilities very seriously. 
1.5 In this policy, third party means any individual or organisation you come into contact with during the course of your work for the Company, and includes business partners and their agents, external funders, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties. 
1.6 References in this policy to obtaining written approval includes obtaining approval by e-mail.  
 
2. WHO IS COVERED BY THE POLICY?  
This policy applies to all individuals working at all levels and grades, and includes all employees (whether permanent, fixed-term or temporary), honorary staff, consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as workers in this policy), The Act applies to conduct both within and outside the UK. 
 
3. WHAT IS BRIBERY?  
A bribe is an inducement or reward offered, promised or provided in order to gain anycommercial, contractual, regulatory or personal advantage. At the end of this document there is a schedule setting out some scenarios that illustrate potential bribery.  

 
4. GIFTS AND HOSPITALITY 
4.1 In addition to the requirements set out below, you must register any gifts or hospitality given or received with an estimated value in excess of £100.00 (or €100.00) with either your Line Manager or The Director. The details of how to do this are set out in Paragraph 9.2 below. Further, you must obtain the written approval (which includes by e-mail) of your Line Manager in relation to any gifts or hospitality given or received with an estimated monetary value in excess of £500.00 (or €500.00) (see paragraph 9.2 below). You may register or obtain consent on a voluntary basis in relation to gifts or hospitality below the relevant figures. Paragraph 4.5 also contains a registration requirement. 4.2 The Company recognises that the practice of the giving and receiving of business gifts or hospitality varies between countries and regions and what may be normal and acceptable in one region may not be in another. The testto be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift or hospitality should always be considered. 
 
Hospitality 
4.3 This policy does not prohibit normal and appropriate hospitality (given and received) to or from third parties, for the purposes of establishing or maintaining good business relationships or improving or maintaining our reputation or image. 
 
Gifts 
4.4 The giving or receipt of gifts is not prohibited, if the following requirements are met: 
4.4.1 it is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or 
retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits; 
4.4.2 it is given in the Company’s name, not in your name; 
4.4.3 it does not include cash or a cash equivalent (such as gift certificates or vouchers); 
4.4.4 it is appropriate in the circumstances. For example, in the UK it is customary for small gifts to be given at Christmas time; 
4.4.5 considering the reason for the gift, it is of an appropriate type and value and given at an appropriate time; and 
4.4.6 it is given openly, not secretly. 
4.5 Gifts should not be offered to, or accepted from, government officials or representatives, or politicians or political parties, without the prior approval of The Line Manager or The Director who can be contacted on gulce.belgin@lunapharmaconsulting.com. Any such gifts must be registered 
regardless of value.  
 
5. WHAT IS NOT ACCEPTABLE? 
It is not acceptable for you (or someone on your behalf) to: 
5.1 give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that either a personal or business advantage will be received, or to reward either a personal or business advantage already given; 
5.2 give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to "facilitate" or expedite a routine procedure; 
5.3 accept payment from a third party that you know or suspect is offered with the expectation that it will obtain either a personal or business advantage for them; 
5.4 accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that either a personal or business advantage will be provided by the Company in return; 
5.5 accept a gift or hospitality from a third party who is tendering for a contract to be awarded by the Company either on its own or jointly with other parties and for a period of three months after the award of the contract; 
5.6 turn a blind eye to any of the above; 
5.7 threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; or 
5.8 engage in any activity that might lead to a breach of this policy. 
 
6. FACILITATION PAYMENTS AND KICKBACKS 
6.1 The Company does not make, and will not accept, facilitation payments or "kickbacks" of any kind. Facilitation payments are typically small, unofficial 
payments made to secure or expedite a routine government action by a government official. They are not commonly paid in the UK but are common in some other jurisdictions. 
6.2 If you are asked to make a payment on the Company’s behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with The Line Manager or The Director. 
6.3 All workers must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by the Company. 
  

 
7. DONATIONS 
We do not make any contributions to political parties. 
 
8. YOUR RESPONSIBILITIES 
8.1 You must ensure that you read, understand and comply with this policy. 
8.2 The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for the Company or under its control. All workers are required to avoid any activity that might lead to, or suggest, a breach of this policy. 
8.3 You must notify either The Line Manager or The Director or follow the steps set out in the Policy on Public Interest Disclosure as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. If you are unsure whether a particular act constitutes bribery or corruption, please contact The Line Manager or The Director. 
8.4 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with other workers if they breach this policy. 
 
9. RECORD-KEEPING 
9.1 The Company must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties. 
9.2 If you are required to register a gift or hospitality under this policy you must complete the Gifts and Hospitality Registration form and send it to either your Line Manager or The Director who will maintain a Register of Gifts and Hospitality (which can consist of storing the forms electronically). You must register any gift or hospitality within 28 days. Requests to your Line Manager for written approval (which includes by e-mail) of gifts or hospitality must be submitted in advance where possible to allow time for a decision to be made. 
9.3 You must ensure that all claims relating to hospitality and gifts and other payments to third parties are submitted in accordance with the relevant Company policy and specifically record the reason for the expenditure. 
9.4 All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept "off-book" to facilitate or conceal improper payments. 
 
10. RISK ASSESSMENT AND KNOWING WHO YOU ARE DEALING WITH 
10.1 The Line Manager or The Director will review annually the corruption and bribery risk that the Company faces. 
10.2 It is also the responsibility of all workers to bring to the attention of The Line Manager or The Director any potential new risk which may arise when it arises, rather than waiting to report it in the annual risk assessment. 
10.3 All workers must understand who they are doing business with and guidance on this issue can be obtained from The Line Manager or The Director. This process is known as due diligence. 
 
11. WHAT TO DO IF YOU BECOME INVOLVED IN BRIBERY OR CORRUPTION 
It is important that you inform The Line Manager or The Director as soon as possible even if you suspect that it may happen in the future. 
 
12. PROTECTION 
12.1 Workers who refuse to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. The Company aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. 
12.2 The Company is committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform The Line Manager or The Director immediately. 
 
13. TRAINING AND COMMUNICATION 
13.1 The Anti-Bribery Policy is made clearly and communicated to all members of staff. 
13.2 Our zero-tolerance approach to bribery and corruption should be communicated to all suppliers, contractors and business partners. A standard Anti
Corruption and Bribery clause should be inserted into all contracts where possible and where not, the contract should contain a clause that provides the Company with the same level of protection as afforded by the standard clause unless otherwise advised by The Line Manager or The Director. 
 
14. WHO IS RESPONSIBLE FOR THE POLICY? 
14.1 The Company Council has overall responsibility for ensuring that this policy complies with our legal and ethical obligations, and that all those under the Company’s control comply with it. 
14.2 The Line Manager or The Director has primary and day-to-day responsibility for implementing this policy, for monitoring its use and effectiveness and dealing with any queries on its interpretation. 
 
15. MONITORING AND REVIEW 
15.1 The Line Manager or The Director will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. All workers are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing. 
15.2 Workers are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to The Line Manager or The Director. 
15.3 This policy does not form part of any employee's contract of employment and it may be amended at any time. You will be notified of any changes to this policy by the placing of updated versions of it on the Company’s website so please refer to the website for the most up to date version. 
 
  
SCHEDULE 
 
Potential risk scenarios:  

i. The following is a list of possible scenarios that may arise during the course of your employment or association with the Company and which may raise concerns under anti-bribery and anti-corruption laws. The list is not exhaustive and is for illustration only. ii. If you encounter any of these situations while working for the Company, you must report them promptly to The Line Manager or The Director OR using the procedure set out in the Policy on Public Interest Disclosure:

a. you become aware that a third party engages in, or has been accused of engaging in, improper business practices;

b. you learn that a third party has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a "special relationship" with foreign government officials;

c. a third party insists on receiving a commission or fee payment before committing to sign up to a contract with us, or carrying out a government function or process for us;

d. a third party asks for payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made;

e. a third party asks that payment be made to a country or geographic location different from where the third party resides or conducts business;

f. a third party asks for an unexpected additional fee or commission to "facilitate" a service;

g. a third party demands lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services;

h. a third party asks that a payment is made to "overlook" potential legal violations;

i. a third party asks that you provide employment or some other advantage to a friend or relative;

j. you receive an invoice from a third party that appears to be non-standard or customised;

k. a third party insists on the use of side letters or refuses to put agreed terms in writing; 
l. you notice that we have been invoiced for a commission or fee payment that appears large given the service stated to have been provided;

m. a third party requests or requires the use of an agent, intermediary, consultant, distributor or supplier that is not typically used by or known to us;

n. you are offered an unusually generous gift or offered lavish hospitality by a third party.

 

25 Eccleston Place

SW1W 9NF

London

Unided Kingdon

© 2019  Luna Pharma Consulting Ltd.