Legal

Pharmaseekers Ltd (“the Company”)

Pharmacies (“Customers”)

Locums, Locum Dispensers, Locum Technicians (“Locums”)

The Company and our data controller are committed to ensuring that your privacy is protected. This privacy policy explains how we use the information we collect about you, how you can instruct us if you prefer to limit the use of that information and procedures that we have in place to safeguard your privacy.

1 The information we collect and how we use it.

1.1 When you register for our service we need to know your name, postal address, e-mail address and telephone number. For Customers we also need to know the address and telephone number of your shops, opening hours, special requirements for Locum provision and details of parking arrangements. For Locums we also require your GPhC registration number, details of your additional qualifications, smart card, passport photograph page, insurance cover and referees including copies of documents where relevant and DBS status, to enable us to provide you with suitable opportunities for Locum work. We routinely contact referees and obtain written references in relation to our Locums.

1.2 We gather this information to allow us to process your registration, to provide Customers with suitable Locums and to provide Locums with suitable opportunities for Locum work. The relevant information is then used by us to provide the service and provide you with statements of your account and to communicate with you on any matter relating to the conduct of your account and the provision of our service in general. We may pass any or all of the personal information we hold for a Locum, including identification documentation, DBS status information and references, to our Customers during the course of providing the service.

1.3 We may also use aggregate information and statistics for the purposes of monitoring website usage in order to help us develop the website and our services and may provide such aggregate information to third parties. These statistics will not include information that can be used to identify any individuals.

1.4 From time to time we may provide your information to our customer service agencies for research and analysis purposes so that we can monitor and improve the services we provide. We or our agents and sub-contractors may contact you by post, e-mail or telephone to ask you for your feedback and comments on our services.

1.5 We may also wish to provide you with information about special features of our website or any other service or products we think may be of interest to you. If you would rather not receive this information please send a an email message to this effect to enquiries@pharmaseekers.co.uk

1.6 We may also want to provide you with related information from third parties we think may be of interest to you. If you would rather not receive this information please send an e-mail to enquiries@pharmaseekers.co.uk

We may also provide your information to carefully selected third parties whose products or services we believe may be of interest to you. If you do not wish us to disclose your information in this way, please send an e-mail enquiries@pharmaseekers.co.uk

1.7 The Company may process personal data relating to Locums and Customers:

1.7.1 in connection with the Company’s business;

1.7.2 in connection with any future proposal to sell or transfer the Company or its respective business (see Clause 4).

1.8 Locums consent to the Company processing data relating to them for legal, personnel, administrative and management purposes and in particular to the processing of any sensitive personal data (as defined in the Data Protection Act 1988 (the “Act”)) relating to the Locum, including, as appropriate, information about the Locum’s:

1.8.1 physical or mental health or condition in order to monitor sickness and take decisions about the Locum’s fitness for work;

1.8.2 racial or ethnic origin or religion or similar information in order to monitor compliance with equal opportunities legislation;

1.8.3 information relating to any criminal proceedings in which the Locum has been involved for insurance purposes and in order to comply with legal requirements and obligations to third parties; and

1.8.4 any other sensitive personal data as defined in the Act.

1.9 Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

2 Our use of cookies and other information gathering technologies.

2.1 When you visit the website we may store some information (commonly known as a “cookie”) on your computer. Cookies are pieces of information that a website transfers to your hard drive to store and sometimes track information about you. Cookies are specific to the server that created them and cannot be accessed by other servers, which means that they cannot be used to track your movements around the web. Passwords and credit card numbers are not stored in cookies. A cookie helps you get the best out of the Site and helps us to provide you with a more customised service. We use cookies for the following purposes:

2.1.1 so that you will not have to re-enter your details each time you visit the website;

2.1.2 to track how our site is used and to improve and update our content.

2.2 You can block or erase cookies from your computer if you want to (your browser’s help screen or manual should tell you how to do this) but certain parts of the website are reliant on the use of cookies to operate correctly and may not work correctly if you set your browser not to accept cookies. Further information is available from this link http://www.aboutcookies.org.

3 How we protect your information.

3.1 The internet is not a secure medium. However we have put in place various security procedures as set out in this policy.

3.2 You have provided your own user name and password at registration and you are responsible for safeguarding these. We have in place security measures to protect the personal data processed. These include a UK Fast managed corporate firewall, with content filtering software, anti-virus and anti-spam software solutions at our remotely hosted server. We also have limited individual access controlled by passwords. Routine backups ensure that in the event of a system failure information can be readily reinstated)

3.3 We also keep your information confidential. The internal procedures of Pharmaseekers cover the storage, access and disclosure of your information. Please refer to clause 1 above.

4 Sale of business.

4.1 If this business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business

5 Updating your details.

5.1 If any of the information that you have provided to us changes you can update the information on line, or if you wish to cancel your registration, please let us know by sending an e-mail to enquiries@pharmaseekers.co.uk or by sending a letter to Website Admin, Pharmaseekers, Suite 309, India Mill, Bolton Road, Darwen, Lancashire, BB3 1AE

5.2 You can find out what personal information we hold about you by writing to Website Admin, Pharmaseekers, Suite 309, India Mill, Bolton Road, Darwen, Lancashire, BB3 1AE We will acknowledge receipt within 10 days and hope to deal with such a request within 40 days. We may charge you a fee for such a request.

6 Your consent.

6.1 By submitting your information you expressly consent to the Company processing and/or transferring your personal data and sensitive personal data in the ways set out above.. If we change our privacy policy we will post the changes on this page, and may place notices on other pages of the website, so that you may be aware of the information we collect and how we use it at all times. We will also e-mail you should we make any changes so that you may consent to our use of your information in that way. Continued use of the service will signify that you agree to any such changes.

6.2 Owing to the global nature of the Internet infrastructure, the information you provide may be transferred in transit to countries outside the European Economic Area that do not have similar protections in place regarding your data and its use as set out in this policy. However, we have taken the steps outlined above to try to improve the security of your information. By submitting your information you consent to these transfers.

7 Data retention

7.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

7.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

8 Your legal rights

8.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data.

• Request access to your personal data.

• Request correction of your personal data

• Request erasure of your personal data

• Object to processing of your personal data

• Request restriction of processing your personal data

• Request transfer of your personal data

• Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact us.

8.2 No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

8.3 What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

8.4 Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

How to contact us.

9 We welcome your views about our website and our privacy policy. If you would like to contact us with any queries or comments please send an e-mail to enquiries@pharmaseekers.co.uk or alternatively write to us at:

PHARMASEEKERS LIMITED

Suite 309

India Mill

Bolton Road

Darwen

Lancashire

BB3 1AE

Pharmaseekers Ltd (“THE COMPANY”)

This Disclaimer sets out important information about www.pharmaseekers.co.uk (“Website”). Please read it carefully as it affects your rights and liabilities under the law. If you do not agree with the Disclaimer, please do not use the Website. If you have any questions about this Disclaimer, please contact enquiries@pharmaseekers.co.uk

1 Use of Website 1.1 This Website is provided to you for your personal use subject to this Disclaimer. By using the Website you agree to be bound by this Disclaimer. 1.2 We may update this Disclaimer from time to time for legal or regulatory reasons or to allow the proper operation of the Website. Any changes will be notified to you via a suitable announcement on the Website. The changes will apply to the use of the Website after we have given you notice. If you do not wish to accept the new Disclaimer you should not continue to use the Website. If you continue to use the Website after the date on which the change comes into effect, your use of the Website indicates your agreement to be bound by the new Disclaimer.

2 Intellectual property The content of the Website is protected by copyright, trademarks, database right and other intellectual property rights. You may retrieve and display the content on the Website on a computer screen, store such content in electronic form on disk (but not on a server or other storage device connected to a network) or print one copy of such content for your own personal, non-commercial use, provided you keep intact all and any copyright and proprietary notices. You may not otherwise reproduce, modify, copy or distribute or use for commercial purposes any of the materials or content on the Website without written permission from the Company.

3 Content of the Website We endeavour to ensure that the contents of this Website are accurate and up-to-date but no warranties or guarantees are made about the information contained herein. 4 Availability of the Website We cannot promise that the Website will be fault-free. If a fault occurs with the Website you should report it to enquiries@pharmaseekers.co.uk and we will attempt to correct the fault as soon as we can. Your access to the Website may be occasionally restricted to allow for repairs, maintenance or the introduction of new content. We will attempt to restore access as soon as we reasonably can.

5 Liability 5.1 The Company accepts no liability for errors or omissions on his Website to the full extent permitted by law. We and our suppliers exclude all warranties, including without limitation, warranties over merchantability, non infringement of third party rights and fitness for a particular purpose. We make no warranties that the accuracy, reliability and completeness or timeliness of the material, information, services, software, text, graphics or links. 5.2 In no event will the Company be liable to any party for any damages whether direct, indirect, incidental, special, consequential or other for any use or inability to use the Website or its contents, or of any hyperlinked website, including, without limitation, any damages for lost profits, business interruption, loss of programmes or other data, even if we are expressly advised of the possibility of such damages. 5.3 Where the Website provides content from other internet sites or resources, the Company tries to ensure that material included on the Website is correct, reputable and of high quality. However, it does not make any warranties or guarantees in relation to that content. If the Company is informed of any inaccuracies in the material on the Website we will attempt to correct the inaccuracies as soon as we reasonably can. 5.4 If we are in breach of this Disclaimer, we will only be responsible for any losses that you suffer as a result and to the extent that they are a foreseeable consequence of both of us at the time you use the Website. Our liability shall not in any event include business losses such as lost data, lost profits or business interruption. 5.5 This clause 4 shall not limit or affect our liability if something we do negligently causes death or personal injury.

6 General 6.1 We may collect information about you. For more information, please see our Privacy Policy 6.2 This Disclaimer will be subject to the laws of England and Wales. If you want to take court proceedings, you must do so within the United Kingdom. 6.3 We make no promise that the materials on the Website are appropriate or available for use in locations outside the United Kingdom, and accessing the Website from territories where its contents are illegal or unlawful is prohibited. If you choose to access the Website from elsewhere, you do so on your own initiative and are responsible for compliance with local laws. 6.4 The Website is owned and operated by Pharmaseekers of Suite 309, India Mill, Bolton Road, Darwen. BB3 1AE. 6.5 If you have any queries please contact enquiries@pharmaseekers.co.uk 6.6 Company Registration No. 4939283; VAT No. 857 976 157 6.7 Last update: 7 July 2008

Pharmaseekers: Customer Terms & Conditions of Service for Pharmacies.

1. The Agency Fee & When it is Payable. 1.1 The Agency Fee is defined in the rate card which is displayed at www.pharmaseekers.co.uk and it is payable by a Customer for the Service. 1.2 The Agency Fee becomes due when Pharmaseekers introduce a Locum to a Customer in order to fill a vacancy. It is payable both in respect of each pharmacy attended by that Locum and for each and every day or part thereof that the Locum works for the Customer. 1.3 The Customer accepts that any contract of employment or engagement between the Customer and the Locum is their entire responsibility and the liability for paying the Locum’s Charge is solely that of the Customer. 1.4 All further employment arranged between the Customer and the same Locum must be arranged through Pharmaseekers. 1.5 The Agency Fee becomes due every day subsequent to the initial day that the same Locum is employed on a temporary basis by the Customer. The Agency Fee is due regardless of whether term 1.4 was complied with. 1.6 If the Locum is employed by the Customer subsequent to the initial introduction on a permanent basis an introduction fee is due to Pharmaseekers. The introduction fee is 10% of the Locum’s gross annual salary and if employed for a period of less than one year, the equivalent annualized salary plus VAT if payable. It must be paid within 1 month of the commencement of permanent employment. 1.7 In the event that a Locum is supplied to a Customer and is introduced by the Customer to a third party which results in the Engagement of the Locum by the third party during the Assignment or within whichever is the longer of either 52 weeks from the start of the first Assignment (each new assignment where there has been a break of more than 42 days (6 weeks) since the end of the previous Assignment shall also be considered to be the ‘first Assignment’ for these purposes); or 39 weeks from the day after the last day the Locum worked on the Assignment The Customer shall be liable to pay a Transfer Fee calculated in accordance with clause 1.6. 1.8 The Customer must pay the Agency Fee when it becomes due. The payment must be made in full within 30 days of the Booked Date, or at such other time, as PSK and the Customer may agree. 1.9 Non-payment of the Agency Fee or an Introduction Fee (due under 1.6) by the due date entitles Pharmaseekers to charge interest at 10% calculated daily from the date the date the relevant fee was due. 1.10 The Agency Fee is not refundable, nor are there any rebates. 2. Liability & Each Party’s Responsibilities 2.1 Pharmaseekers will use all reasonable endeavours to ensure the suitability of any Locum introduced to the Customer by obtaining confirmation of the Locum ’s identity, confirmation that the Locum has the experience, training, qualifications and any authorisation which the hirer considers are necessary, or which the worker needs to have by law or by the requirements of any professional body, such as the GPHC in order to carry out the work, two references from Persons not related to the Locum and any authorisation which the Customer considers necessary or which may be required by law or by any professional body; and that the Locum is willing to work in the position which the Customer seeks to fill. 2.2 At the same time as proposing a Locum to the Customer the Agency shall inform the Customer of such matters in clause 2.1 as they have obtained confirmation of. Where such information is not given in paper form or by electronic means it shall be confirmed by such means by the end of the third business day (excluding Saturday, Sunday and any public or Bank holiday) following save where the Locum is being proposed for a position which is the same as one in which the Locum has worked within the previous five business days and such information has already been given to the Customer 2.3 The Agency endeavours to take all such steps as are reasonably practicable to ensure that the Customer and Locum are aware of any requirements imposed by law or any professional body to enable the Locum to work in the position which the Customer seeks to fill. 2.4 Notwithstanding clauses 2.1, 2.2, and 2.3 above the Customer shall satisfy itself as to the suitability of the Locum and the Customer shall take up any references provided by the Locum to it or the Agency before engaging such Locum. The Customer is responsible for obtaining work permits and/or such other permission to work as may be required, for the arrangement of medical examinations and/or investigations into the medical history of any Locum , and satisfying any medical and other requirements, qualifications or permission required by law of the country in which the Locum is engaged to work 2.5 Where such information is not given in paper form or by electronic means it shall be confirmed by such means by the end of the third business day (excluding Saturday, Sunday and any public or Bank holiday) following save where the Locum is being proposed for a position which is the same as one in which the Locum has worked within the previous five business days and such information has already been given to the Customer. 2.6 The Customer accepts responsibility to ensure that the premises in which the Locum will work complies with the standard laid down in the GPhC’s Medical Ethics and Practice Guide, with all relevant statutory requirements and guidelines and is suitable for the purposes of employment. Pharmaseekers accept no liability for any loss resulting from non-compliance with this provision. 2.7 Pharmaseekers accept no liability for any loss or damage, whether to property, loss of profits or for any injury caused to any person, resulting from the acts or omissions of the Locum whether these acts or omissions were fraudulent, negligent or through any other cause. 2.8 In any event Pharmaseekers liability for any breach of the terms whatsoever is limited to the Agency Fee payable. 2.9 The customer must maintain full professional indemnity insurance cover with an insurance company of good repute. Pharmaseekers accept no liability for any loss resulting from non-compliance with this provision. 3. Confidentiality 3.1 Pharmaseekers agree to keep details of both Customers and Locums confidential save for the purposes of arranging work placements in accordance with the provisions of this agreement. 3.2 The Customer must keep confidential the terms of this contract and the ongoing business relationship between Pharmaseekers and the Customer. The details of individual Locum s must not be forwarded on to any prospective employer of the Locum nor may the details be used to arrange employment in breach of 1.4. 4. Effect of Notification of Terms and Conditions. 4.1 These terms and conditions shall prevail over any terms and conditions of the Customer. 4.2 No variation or alteration to these Terms shall be valid unless the details of such variation are agreed between the Agency and the Client and are set out in writing and a copy of the varied terms is given to the Client stating the date on or after which such varied terms shall apply. 4.3 By accepting these terms and conditions you agree that we may collect, store and use information about you in accordance with our privacy policy which is found on our Website or a copy is available at your request. You acknowledge and agree to be bound by the terms of our privacy policy. 4.4 These terms and conditions, save for express notification to the contrary by Pharmaseekers, form the standard terms and conditions for all contracts to be formed between the Customer and Pharmaseekers with regard to the Service. 5. Interpretation. 5.1 “The Agency Fee” The fee to be paid to Pharmaseekers by the Customer for the Service. 5.2 “Booked Date” A day on which the Locum undertakes a work placement for a Customer. 5.3 “The Contract” The contract between Pharmaseekers and a Customer in respect of the Service 5.4 “Customer” Any and all persons bodies and/or organisations with whom Pharmaseekers contract to provide the Service, including a subsidiary or associated company. 5.5 “Locum” The Pharmacist, Pharmacy Technician or Pharmacy Dispenser provided by Pharmaseekers to the Customer. 5.6 “The Locum’s Charge” Shall mean the charge payable by the Customer to the Locum directly 5.7 “The Service” The service of introducing Locums to Customers. The service that Pharmaseekers will provide will be that of an Employment agency.

PHARMASEEKERS: TERMS AND CONDITIONS OF SERVICE, LOCUM PHARMACISTS, TECHNICIANS AND DISPENSERS

1. Supply of the Service 1.1 In consideration for the Locum agreeing to be introduced to Pharmacies as advised by Pharmaseekers, Pharmaseekers shall provide the Service to the Locum subject to these Terms. Any changes or additions to the Service or these Terms must be agreed in writing by Pharmaseekers and the Locum. Pharmaseekers will not make a charge to the Locum for this service.

1.2 The Service shall be provided in accordance with the terms and conditions contained on Pharmaseekers current Website and / or other published literature relating to the Service that is available from time to time, subject to these Terms. Where a conflict arises, these Terms shall take precedent.

1.3 Further details about the Service, and advice or recommendations about its provision or utilisation, which are not given on the Pharmaseekers Website or other promotional literature, may be made available on written request. 1.4 Pharmaseekers may at any time without notifying the Locum make any changes to the Service which are necessary to comply with any applicable safety or other statutory requirements, or which do not materially affect the nature or quality of the Service. 1.5 Nothing in this Agreement obliges Pharmaseekers to introduce the Locum to a Pharmacy and any such introduction is entirely at Pharmaseekers discretion.

2. Liability and Each Party’s Responsibilities.

2.1 The Locum accepts that the contract of employment or engagement between the Pharmacist and the Pharmacy is their entire responsibility and the liability for paying or providing the Locum’s remuneration is solely that of the Pharmacy. 2.2 Pharmaseekers accept no responsibility for and make no warranty or assurance that the premises in which the Pharmacist will work complies with the standard laid down in the GPhC’s Medical Ethics and Practice Guide nor with any relevant statutory guidelines. Pharmaseekers accept no liability for any loss resulting from non-compliance with this provision.

2.3 Pharmaseekers accept no liability for any loss or damage, whether to property, loss of profits or for any injury caused to any person, resulting from the acts or omissions of the Pharmacy whether these acts or omissions were fraudulent, negligent or through any other cause.

2.4 It is the responsibility of the Pharmacy to maintain full professional indemnity insurance cover with an insurance company of good repute. Pharmaseekers accept no liability to the Locum for any loss resulting from non-compliance with this provision.

2.5 The Locum shall ensure that he is fully and effectively registered and legally authorised to provide all Locum services in the United Kingdom and that he maintains his appropriate qualifications and membership of all and any necessary statutory or professional bodies.

2.6 The Locum shall at all times when undertaking work for a Pharmacy display his GPhC Registration Certificate and when appropriate his Responsible Pharmacist notice. The Locum shall at all times be punctual and act at all times in a professional and appropriate manner.

2.7 Once the Locum has agreed to a placement with a Pharmacy it is that locum’s responsibility to attend at the agreed date and time. There is no obligation for a locum to accept any vacancy offered by Pharmaseekers but upon acceptance of a vacancy by the locum and confirmation by the customer a binding contract exists unless agreement to cancel the booking is given by the customer. A locum may be required to attend an alternative pharmacy in order to help Pharmaseekers or a customer provided the request is reasonable.

2.8 The Locum accepts that having accepted a booking from Pharmaseekers any future booking with that Customer will be made via Pharmaseekers. In the event that the Customer approaches the Locum directly with an offer of work the Locum will notify Pharmaseekers who will be entitled to charge their standard commission for such a booking. Similarly in the event of an offer of full time work with the Customer the Locum will notify Pharmaseekers who will be entitled to charge the Customer the appropriate fee.

3. Effect of Notification of Terms and Conditions.

3.1 These terms and conditions shall prevail over any terms and conditions of the Locum.

3.2 These terms and conditions may only be varied with written consent of a representative of Pharmaseekers.

3.3 These terms and conditions, save for express notification to the contrary by Pharmaseekers, form the standard terms and conditions for all contracts to be formed between the Locum and Pharmaseekers with regard to the introduction of the Locum to the Pharmacy.

3.4 By accepting these terms and conditions the Locum agrees that we may collect, store and use information about him in accordance with our privacy policy which is found on our Website or a copy is available upon request. The Locum acknowledges and agrees to be bound by the terms of our privacy policy.

3.5 These terms and conditions shall be governed and interpreted in accordance with English Law and the English Courts shall have jurisdiction to resolve any dispute hereunder.

4. Interpretation

In these terms and conditions:

4.1 “CONTRACT” means the contract for the provision of the Service.

4.2 “PHARMACY” means the person body or organisation to whom the Pharmacist is introduced as a result of the Service.

4.3 “Pharmaseekers” are the firm with which The Pharmacist contracts for the provision of the Service.

4.4 “LOCUM” means the person for whom Pharmaseekers have agreed to provide the Service in accordance with these Terms and LOCUM shall include Locum Pharmacists, Locum Pharmacy Technicians and Locum Pharmacy Dispensers

4.5 “SERVICE” this is the service of introducing the Locum to the Pharmacy for the purposes of filling a temporary work placement. The service that Pharmaseekers will provide will be that of an Employment agency.

4.6 “WEBSITE” means www.pharmaseekers.co.uk

4.7 “Customer” means any and all persons bodies and/or organisations with whom Pharmaseekers contract to provide the Service

5. Severance

(a) If any provision or part-provision of the Contract is or becomes invalid, illegal or unenforceable, it shall be deemed modified to the minimum extent necessary to make it valid, legal and enforceable. If such modification is not possible, the relevant provision or part-provision shall be deemed deleted. Any modification to or deletion of a provision or part-provision under this clause shall not affect the validity and enforceability of the rest of the Contract.

(b) If one party gives notice to the other of the possibility that any provision or part-provision of this Contract is invalid, illegal or unenforceable, the parties shall negotiate in good faith to amend such provision so that, as amended, it is legal, valid and enforceable, and, to the greatest extent possible, achieves the intended commercial result of the original provision.

Complaints Policy Pharmaseekers is committed to providing a high level service to our customers. If you do not receive satisfaction from us we need you to tell us about it. This will help us to improve our standards.

Complaints Procedure If you have a complaint, please contact Rebecca West, Director. You can write to her at: Suite 309, India Mill, Bolton Road, Darwen, Lancashire, BB3 1AE.

Next steps 1 – We will send you a letter acknowledging your complaint and asking you to confirm or explain the details set out. We will also let you know the name of the person who will be dealing with your complaint. You can expect to receive our letter within 5 days of us receiving your complaint. 2 – We will record your complaint in our central register within a day of having received it. 3 – We will acknowledge your reply to our acknowledgment letter and confirm what will happen next. You can expect to receive our acknowledgement letter within 5 days of your reply. 4 – We will then start to investigate your complaint. This will normally involve the following steps We may ask the member of staff who dealt with you to reply to your complaint within 5 days of our request We will then examine the member of staff’s reply and the information you have provided for us. If necessary we may ask you to speak to them. This will take up to 4 days from receiving their reply 5 – Rebecca West will then invite you to meet her to discuss and hopefully resolve your complaint. She will do this within 5 days of the end of our investigation. 6 – Within 2 days of the meeting Rebecca West will write to you to confirm what took place and any solutions she has agreed with you. If you do not want a meeting or it is not possible, Rebecca West will send you a detailed reply to your complaint. This will include her suggestions for resolving the matter. She will do this within 5 days of completing her investigation. 7 – At this stage, if you are still not satisfied you can write to us again. Another Director of the company will review Rebecca West’s decision within 10 days. 8 – We will let you know of the outcome of this review within 5 days of the end of the review. We will write to you confirming our final position on your complaint and explaining our reasons. If you are still not satisfied, you can contact the Employment Agencies Standards Office at the Department for Business, Enterprise and Regulatory Reform (DBERR.)

If we have to change any of the time scales above, we will let you know and explain why.

1 GENERAL 1.1 Pharmaseekers embraces diversity and will seek to promote the benefits of diversity in all of our business activities. We will seek to develop a business culture that reflects that belief. We will seek to widen the media in which we recruit to ensure as diverse an employee and candidate base as possible. We will strive to make sure that our clients meet their own diversity targets. 1.2 Pharmaseekers is committed to diversity and will promote diversity for all employees, workers and applicants and shall adhere to such a policy at all times. We will review on an on-going basis all aspects of recruitment to avoid unlawful or undesirable discrimination. Pharmaseekers will treat everyone equally irrespective of sex, sexual orientation, gender reassignment, marital or civil partnership status, age, disability, colour, race, nationality, ethnic or national origin, religion or belief, political beliefs or membership or non-membership of a Trade Union or spent convictions, and places an obligation upon all staff to respect and act in accordance with the policy. Pharmaseekers is committed to providing training for its entire staff in equal opportunities practice. 1.3 Pharmaseekers shall not discriminate unlawfully when deciding which candidate/temporary worker is submitted for a vacancy or assignment, or in any terms of employment or terms of engagement for temporary workers. Pharmaseekers will ensure that each candidate is assessed only in accordance with the candidate’s merits, qualifications and abilities to perform the relevant duties required by the particular vacancy. 1.4 Pharmaseekers will not accept instructions from clients that indicate an intention to discriminate unlawfully.

2 DISCRIMINATION Unlawful discrimination occurs in the following circumstances: 2.1Direct discrimination Direct discrimination occurs where one individual treats or would treat another individual less favourably on grounds of sex, sexual orientation, gender reassignment, marital or civil partnership, age, disability, colour, race, nationality, ethnic or national origin, religion or belief, political beliefs (“the protected categories”). It is unlawful for a recruitment consultancy to discriminate against a person on the grounds of a protected category: –

• in the terms on which the recruitment consultancy offers to provide any of its services

• by refusing or deliberately omitting to provide any of its services

• in the way it provides any of its services

Direct discrimination would also occur if a recruitment consultancy accepted and acted upon a job registration from an employer which states that certain persons are unacceptable due to a protected category, unless one of the exceptions applies, for instance, the job demands a genuine occupational requirement or in the case of age, the discrimination can be lawfully justified. 2.2 Indirect Discrimination Indirect discrimination occurs where an agency or employer applies a provision, criterion or practice generally, which disadvantages a minority group in the community on the basis of a protected category. Indirect discrimination would also occur if a recruitment consultant accepted and acted upon an indirectly discriminatory instruction from an employer. If the vacancy requires characteristics which amount to a genuine occupational requirement or the instruction is lawfully discriminatory due to a statutory exception or objective justification, Pharmaseekers will not deal further with the vacancy unless the client provides written confirmation of such genuine occupational requirement, exception or justification. 2.3 DISABLED PERSONS 2.3.1 Direct Discrimination Direct discrimination against a person occurs where, if for a reason which relates to the disabled person’s disability, an individual: treats him less favourably than he treats, or would treat others to whom that reason does not or would not apply, and the employer cannot show that the treatment in question is justified. Or if on the ground of a disabled person’s disability, he treats the disabled person less favourably than he treats or would treat a person not having that particular disability, whose relevant circumstances, including his abilities, are the same as, or not materially different from, those of the disabled person. This type of direct discrimination can never be justified.

2.3.2 Duty to make reasonable adjustments and to provide auxiliary aids and services. This is a similar protection to indirect discrimination in the other protected categories. Where a provision, criterion or practice applied by or on behalf of an employer, or any physical feature of the employer’s premises, places a disabled person at a substantial disadvantage in comparison with persons who are not disabled, it will be the duty of an employer to take such steps as are reasonable, in all the circumstances of the case, to remove the provision, criterion, practice or physical feature.

Agencies must take reasonable steps to provide auxiliary aids or services if this would make it easier for the disabled person to use their services. For instance, an appropriate auxiliary aid or service can include the provision of information on audiotape or provision of a sign language interpreter. Pharmaseekers will not discriminate against a disabled person on the grounds of disability –

• in the arrangements i.e. application form, interview or arrangements for selection for determining to whom a job should be offered

• or in the terms on which employment or engagement of temporary workers is offered

• by refusing to offer, or deliberately not offering the disabled person a job for reasons connected with their disability

• or in the opportunities afforded to the person for receiving any benefit, or by refusing to afford, or deliberately not affording him or her any such opportunity; or

• by subjecting him or her to any other detriment (detriment will include refusal of training or transfer, demotion, reduction of wage, or harassment).

Pharmaseekers will accordingly make career opportunities available to all people with disabilities and every practical effort will be made to provide for the needs of staff, candidates and clients.

Wherever possible Pharmaseekers will make reasonable adjustments to hallways, passages and doors in order to provide and improve means of access for disabled employees and workers. However, this may not always be feasible, due to circumstances creating such difficulties as to render such adjustments as being beyond what is reasonable in all the circumstances.

3 AGE DISCRIMINATION Pharmaseekers will not discriminate directly or indirectly, harass or victimise any person on the grounds of their age. We will encourage clients not to include any age criteria in job specifications and every attempt will be made to persuade clients to recruit on the basis of competence and skills and not age. Pharmaseekers is committed to recruiting and retaining employees whose skills, experience, and attitude are suitable for the requirements of the various positions regardless of age. No age requirements will be stated in any job advertisements on behalf of the company. Pharmaseekers will request age as part of its recruitment process but such information will not be used as selection, training or promotion criteria or in any detrimental way and is only for compilation of personal data, which the company holds on all employees and workers and as part of its equal opportunities monitoring process.

4 PART-TIME WORKERS This Diversity Policy also covers the treatment of those employees and workers who work on a part-time basis, Pharmaseekers recognises that it is an essential part of this policy that part time employees are treated on the same terms, with no detriment, as full time employees (albeit on a pro rata basis) in matters such as rates of pay, holiday entitlement, maternity leave, parental and domestic incident leave and access to our pension scheme. Pharmaseekers also recognises that part time employees must be treated the same as full time employees in relation to training and redundancy situations.

5 HARASSMENT POLICY 5.1 Pharmaseekers is committed to providing a work environment free from unlawful harassment on grounds of sex, sexual orientation, gender reassignment, marital or civil partnership status, age, disability, colour, race, nationality, ethnic or national origin, religion or belief, political beliefs or any other basis protected by legislation is unlawful and will not be tolerated by Pharmaseekers. 5.2 This policy prohibits unlawful harassment by any employee or worker of Pharmaseekers. 5.3 Examples of prohibited harassment are: – 5.3.1 Verbal or written conduct containing derogatory jokes or comments 5.3.2 Slurs or unwanted sexual advances 5.3.3 Visual conduct such as derogatory or sexually orientated posters 5.3.4 Photographs, cartoons, drawings or gestures which some may find offensive 5.3.5 Physical conduct such as assault, unwanted touching, or any interference because of sex, race or any other protected category basis 5.3.6 Threats and demands to submit to sexual requests as a condition of continued employment or to avoid some other loss, and offers of employment benefits in return for sexual favours 5.3.7 Retaliation for having reported or threatened to report harassment 5.4 If you believe that you have been unlawfully harassed, you should make an immediate report to Rebecca West followed by a written complaint as soon as possible after the incident. Your complaint should include:

• Details of the incident

• Name(s) of the individual(s) involved

• Name(s) of any witness(es)

5.5 Pharmaseekers will undertake a thorough investigation of the allegations. If it is concluded that unlawful harassment has occurred, remedial action will be taken. 5.6 Any employee(s) who Pharmaseekers finds to be responsible for unlawful harassment will be subject to the disciplinary procedure and any sanction may include termination. [A person who discriminates or harasses may be personally liable for payment of compensation to the person offended, in addition to any compensation payable by Pharmaseekers. There is no statutory cap on the amount of compensation which may be awarded in discrimination cases. Under the Criminal Justice Act 1994, harassment became a criminal offence, punishable by a fine of up to £5,000 and/or a prison term of up to 6 months. Under the Protection from Harassment Act 1997, the penalties for aggravated harassment are an unlimited fine and/or 5 years imprisonment.]

6 GENDER REASSIGNMENT POLICY 6.1 Pharmaseekers recognises that any employee or worker may wish to change their gender during the course of their employment with the Company. 6.2 Pharmaseekers will support any employee or worker through the reassignment provided that full medical counselling has been undertaken and Pharmaseekers has access to any relevant medical reports. 6.3 Pharmaseekers will make every effort to try to protect an employee or worker who has undergone, is undergoing or intends to undergo gender reassignment, from discrimination or harassment within the workplace. 6.4 All employees and workers will be expected to comply with Pharmaseekers policy on harassment in the workplace. Any breach of such a policy will lead to the appropriate disciplinary sanction. 6.5 Where an employee is engaged in work where the gender change imposes genuine problems Pharmaseekers will make every effort to reassign the employee or worker to an alternative role in the Company, if so desired by the employee. 6.6 Any employee or worker suffering discrimination on the grounds of gender reassignment should make recourse to the Company’s grievance procedure.

7 COMPLAINTS AND MONITORING PROCEDURES 7.1 Pharmaseekers has in place procedures for monitoring compliance with this policy and for dealing with complaints of discrimination. These are available from Rebecca West. 7.2 Any discrimination complaint will be investigated fully.