Legal.

Terms Of Use.

Last reviewed May 2022

1. Introduction

  • Welcome to the Pi Healthcare website; www.pi-healthcare.com (our site) is a site operated by Pi Healthcare Limited ("We","Our","Us"). We are a limited company registered in England and Wales under company number 07526749 and have our registered office and main trading address at Marsel House, Stephensons Way, Ilkley, LS29 8DD
  • These terms of use govern your use of this website; by using this website you confirm that you accept these terms of use in full. If you disagree with these terms of use, or any part of these terms of use you must not use this website.
  • Our services are provided to other businesses or organisations only. We do not provide any services to consumers, and as such our website is not directed to consumers.
  • This website uses cookies. By using this website and agreeing to these terms of use, you consent to our use of cookies in accordance with the terms of our privacy policy, which is available on our site.
  • We will only use your personal information in accordance with the privacy policy that is available on our site.
  • We may amend these terms from time to time.
  • We may also update and change our site from time to time.
  • We may suspend or withdraw our site at any time.
  • We may terminate or suspend your access to our website immediately, without prior notice or liability, for any reason whatsoever, including without limitation if You breach these terms of use. Upon termination, your right to use the website will cease immediately.

2. License to use website

  • Unless otherwise stated, We are the owner or the licensee of all intellectual property rights in our site, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved. Licence to use of the website does not negate our property rights.
  • You may view, download for caching purposes only, and print pages from the website for the user's personal use, subject to the restrictions set out below and elsewhere in the terms of use.
  • You must not:
  • ~~Republish material from this website (including republishing to another website);
  • ~~Sell, rent or sub-licence material from this website;
  • ~~Show any material from the website in public;
  • ~~Reproduce, duplicate, copy, or otherwise exploit material on this website for a commercial purpose without obtaining a prior licence to do so from us or our licensors;
  • ~~Edit or otherwise modify any material on the website;
  • ~~Redistribute material from this website;
  • ~~Use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text.
  • If you print off, copy or download any part of our site in breach of these terms of use, your right to use our site will cease immediately and you must, at our option, return or destroy any copies of the materials you have made. We will also have other rights against you in these circumstances, for example the right to sue you for copyright infringement. All such rights are reserved.

3. Acceptable Use

  • You must not use this website in any way that causes, or may cause, damage to the website or impairment of the availability or accessibility of the website; or in any way which is unlawful, illegal, fraudulent or harmful, or in connection with any unlawful, illegal, fraudulent or harmful purpose or activity.
  • You must not use this website to copy, store, host, transmit, and, use, publish or distribute any material which consists of (or is linked to) any spyware, computer virus, trojan horse, keystroke logger, rootkit or other malicious computer software.
  • You must not conduct any systemic or automated data collection activities (including without limitation scraping, data mining, data extraction) on or in relation to this website without Pi Healthcare's express written consent.
  • You are also responsible for ensuring that all persons who access our site through your internet connection are aware of these terms of use and other applicable terms and conditions, and that they comply with them.
  • You must not attempt to gain unauthorised access to our site, the server on which our site is stored or any server, computer or database connected to our site.
  • You must not attack our site via a denial-of-service attack or a distributed denial-of-service attack. By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our site will cease immediately.
  • You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it.
  • You must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists. We reserve the right to withdraw linking permission without notice.

4. User Content

  • In these terms of use, “your user content” means material (including without limitation text, images, audio material, video material and audio-visual material) that you submit to this website, for whatever purpose.
  • You grant to Pi Healthcare consent to collect, process or transfer any user content or personal data in accordance with our privacy policy.
  • Your user content must not be illegal or unlawful, must not infringe any third party’s legal rights, and must not be capable of giving rise to legal action whether against you or Pi Healthcare or a third party (in each case under any applicable law).
  • You must not submit any user content to the website that is or has ever been the subject of any threatened or actual legal proceedings or other similar complaint.
  • Pi Healthcare reserves the right to edit or remove any material submitted to this website, or stored on Pi Healthcare’s servers, or hosted or published upon this website.

5. No Warranties

  • The website is provided "as is" without any representation or warranties, express or implied. Pi Healthcare makes no representations or warranties in relation to this website or the information and materials provided on this website.
  • Without prejudice to the generality of the foregoing paragraph, Pi Healthcare does not warrant that:
  • ~~The website will be constantly available, or available at all; or
  • ~~The information on this website is complete, true, accurate, or non-misleading; or
  • ~~The information on this website constitutes, or is meant to constitute, advice of any kind.

6. Links to Other Websites and Third Party Content

  • Where our site contains links to other sites and resources provided by third parties, these links are provided for your information only. Such links should not be interpreted as approval by us of those linked websites or information you may obtain from them. We have no control over the contents of those sites or resources.

7. Limitations of Liability

  • Pi Healthcare will not be liable to you for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with:
  • ~~Use of, or inability to use, our site; or
  • ~~use of or reliance on any content displayed on our site.
  • ~~In particular, we will not be liable for:
  • ~~any business losses, loss of revenue, income, profits;
  • ~~loss of contracts or business relationships;
  • ~~loss or corruption of information or data;
  • ~~business interruption;
  • ~~loss of anticipated savings;
  • ~~loss of business opportunity, goodwill or reputation; or
  • ~~any indirect or consequential loss or damage.
  • These limitations of liability apply even if Pi Healthcare has been expressly advised of the potential loss.

8. Exceptions

  • Nothing in this website disclaimer will exclude or limit any warranty implied by law that it would be unlawful to exclude or limit; and nothing in this website disclaimer will exclude or limit Pi Healthcare’s liability in respect of any:
  • ~~Death or personal injury caused by Pi Healthcare’s negligence;
  • ~~Fraud or fraudulent misrepresentation on the part of Pi Healthcare; or
  • ~~Matter which it would be illegal or unlawful for Pi Healthcare to exclude or limit, or to attempt or purport to exclude or limit, its liability.

9. Reasonableness

  • By using this website, you agree that the exclusions and limitations of liability set out in this website disclaimer are reasonable
  • If you do not think they are reasonable, you must not use this website.

10. Indemnity

  • You hereby indemnify Pi Healthcare and undertake to keep Pi Healthcare indemnified against any losses, damages, costs, liabilities and expenses (including without limitation legal expenses and any amounts paid by Pi Healthcare to a third party in settlement of a claim or dispute on the advice of Pi Healthcare’s legal advisers) incurred or suffered by Pi Healthcare arising out of any breach by you of any provision of these terms of use.

11. Breaches of these terms of use

  • Without prejudice to Pi Healthcare’s other rights under these terms of use, if you breach these terms of use in any way, Pi Healthcare may take such action as Pi Healthcare deems appropriate to deal with the breach, including suspending your access to the website, prohibiting you from accessing the website, blocking computers using your network from accessing the website, contacting your internet service provider to request that they block your access to the website and/or bringing court proceedings against you.

12. Variation

  • Pi Healthcare may revise these terms of use from time-to-time. Revised terms of use will apply to the use of this website from the date of the publication of the revised terms of use on this website. Please check this page regularly to ensure you are familiar with the current version.

13. Assignment

  • Pi Healthcare may transfer, sub-contract or otherwise deal with Pi Healthcare’s rights and/or obligations under these terms of use without notifying you or obtaining your consent.
  • You may not transfer, sub-contract or otherwise deal with your rights and/or obligations under these terms of use.

14. Severability

  • If a provision of these terms of use is determined by any court or other competent authority to be unlawful and/or unenforceable, the other provisions will continue in effect. If any unlawful and/or unenforceable provision would be lawful or enforceable if part of it were deleted, that part will be deemed to be deleted, and the rest of the provision will continue in effect.

15. Which country's laws apply to any disputes?

  • These terms of use, their subject matter and their formation (and any non-contractual disputes or claims) are governed by English law. We both agree to the exclusive jurisdiction of the courts of England and Wales.

16. Entire Agreement

  • These terms of use, together with our privacy policy constitute the entire agreement between you and Pi Healthcare in relation to your use of this website, and supersede all previous agreements in respect of your use of this website.

Privacy Policy.

Last reviewed May 2022

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Pi Healthcare Limited collects and processes your personal data, however you provide it to us.  This notice also sets out how we deal with the personal data of third party stakeholders and key opinion leaders (“Third Party Personal Data”) that we may provide to our clients as part of our services.  

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.  

Controller

Pi Healthcare Limited is the controller and is responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy notice).  

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.  

Contact details

Email address: [email protected]

Postal address: Wells Road Business Centre, Ilkley, West Yorkshire LS29 9JB  

We also operate the website at www.pi-healthcare.com.  

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.  

Changes to the privacy notice and your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.  

We reserve the right to make changes to this privacy notice at any time.  

2. The personal data we collect

Your Personal Data

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).  

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:  

  • Identity Data includes first name, last name and title.  
  • Contact Data includes business contact address, email address and telephone numbers.

Transaction Data includes details of services you have purchased or otherwise received from us.

  • Technical Data includes browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
  • Financial Data includes your bank account details.  
  • Marketing and Profile Data includes your preferences in receiving marketing from us, your interests and feedback.  

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.  

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.  Please also note that we do not knowingly collect data relating to children.  

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you or to provide you with services you have requested, and you fail to provide that data when requested, we may not be able to perform the contract we have or to provide you with the services you have requested from us. In this case, we may have to cancel the contract in question that you have with us but we will notify you if this is the case at the time.    

Third Party Personal Data

Third Party Personal Data we collect includes Contact Data and Identity Data as described above (but in this context including job title/role, photographs (published by the data subject or on his/her behalf), and details of professional engagements and affiliations).

3. How do we collect personal data?

Your Personal Data

We use different methods to collect data from and about you including through:  

  • Direct interactions. You may give us your data by corresponding with us by post, phone, email or otherwise.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources.  

Third Party Personal Data

We only collect Third Party Personal Data from publicly available sources on the internet. Generally, this data is made available on the internet by the data subjects (i.e. the individuals) themselves, or by organisations with which they are involved (including their employer) on their behalf, in order to promote their clinical expertise. We collect this data from the internet (or ask third parties (who may be located outside of the European Economic Area) to do so on our behalf), consider it, and provide our clients with our advice upon it.  

4. How we use personal data

Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:  

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.  
  • Where we need to comply with a legal or regulatory obligation.  

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.  

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Third Party Personal Data

We process the Third Party Personal Data that we collect on the lawful basis that it is necessary for our legitimate business interests. Our processing of Third Party Personal Data is fundamental to the services that we provide. Furthermore, we believe that the Third Party Personal Data we provide to our clients is also necessary for our clients’ own legitimate business interests in identifying the relevant stakeholders and key opinion leaders (“KOLs”) with whom they need to engage to develop their own products and services. Those KOLs make information about their clinical excellence publicly available in order that (amongst other reasons) those in the pharmaceutical and other clinical industries (including our clients) can identify them as KOLs and can engage with them.  

Marketing  

If we send you marketing communications, you can ask us to stop sending them at any time by following the opt-out links on any marketing communication sent to you or by contacting us at any time.  

Where you opt out of receiving these marketing communications, this will not apply to personal data that we process and use on a different lawful basis.  

We will not share your personal data with any third party for marketing purposes.  

Our Website - Cookies

We use cookies on our website and on our online subscription portal, but they do not collect personal data. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.  

Our Website - Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.  

Suppliers

If you are a supplier to us, you will be asked to supply certain personal data to us and we will process that personal data for the purposes of the contract that you and we enter into for the supply of your products/services.  

Change of purpose  

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.  

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.  

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.  

5. Disclosures of personal data

Your Personal Data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.  

  • Service providers (acting as processors) who provide services to us, including IT service providers (in particular for systems maintenance, hosting and trouble-shooting), and providers of our cloud-based accounting platform.  
  • Professional advisers (acting as processors or joint controllers) including bankers, lawyers, HR consultants, accountants and insurers who provide banking, consultancy, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities (acting as processors or joint controllers) who may require reporting of processing activities in certain circumstances.  
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.  

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.  

 

Third Party Personal Data

We share Third Party Personal Data with our clients (acting as joint controllers), for the purposes of providing our services to them. This data is provided in a number of different forms including through a secure online subscription portal. We may also provide Third Party Personal Data to those third parties mentioned above.

6. International transfers

Third Party Personal Data

We share Third Party Personal Data with our clients for the purpose of providing our services to them. Occasionally this may involve a transfer of that personal data outside the European Economic Area (EEA). Whenever we transfer personal data out of the EEA, we seek to ensure a similar degree of protection is afforded to it by ensuring that safeguards are implemented, for example (in respect of US-based clients) by checking that the recipients of such personal data are part of the EU/US Privacy Shield (which requires them to provide similar protection to personal data shared between the Europe and the US).  

Your Personal Data

Our service providers (for example Zero, a provider of our cloud-based accounting platform) may transfer personal data outside the EEA.  Where they do so, they will ensure that personal data is adequately protected by only transferring personal data to countries that have been identified as having adequate protection for EEA personal data, or by only transferring personal data where approved transfer mechanisms having been put in place to protect the personal data (such as approved Standard Contract Clauses or EU/US Privacy Shield certification).  

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.  

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.  

8. Data retention

How long will you use my personal data for?

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.  

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.  

Please note that by law we have to keep basic information about our clients (including certain Contact, Identity and Transaction Data) for 7 years after they cease being clients, for tax purposes. This includes subscribers to our online subscription portal.

We retain Third Party Personal Data for up to 2 years after the end of our project/engagement with the relevant client, or at the end of the relevant client’s subscription to our online subscription portal (for whom we originally collected that Third Party Personal Data).  

We keep personal data relating to our suppliers for longer, as it is in both our interests and theirs that they remain on our system and potentially available for work from us.    

In some circumstances you can ask us to delete your data: see below for further information.  

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.  

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the further information towards the bottom of this privacy policy. If you wish to exercise any of these rights, please contact our data privacy manager.  

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.  

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.  

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.  

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.  

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.  

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.  

YOUR LEGAL RIGHTS

You have the right to:  

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.  

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.  

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.  

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.  

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.  

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.  

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Anti-bribery and Corruption Policy.

Last reviewed May 2022

1. Policy Statement

1.1 Pi Healthcare is committed to applying the highest standards of ethical conduct and integrity in its business activities in the UK and overseas. Every employee and individual acting on Pi Healthcare’s behalf is responsible for maintaining our reputation and for conducting company business honestly and professionally.

1.2 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 wherever we operate.

1.3 The purpose of this policy statement is to:

a) set out our responsibilities, and of those working or providing services for us, (which for the purpose of the Bribery Act includes service providers of Pi Healthcare), in observing and upholding our position on bribery and corruption;

b) provide information and guidance as to how we expect those working for us to conduct themselves and how to recognise and deal with bribery and corruption issues; and

c) how to raise concerns with us including any breaches of this policy statement

1.4 Pi Healthcare’s Management Committee are committed to implementing and enforcing effective systems throughout Pi Healthcare.

2. What is bribery?

A bribe, broadly, is an inducement or reward offered, requested, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage. This can be in the context of giving or receiving. An offence is committed when the bribe is coupled with an intention of inducing, a reward for or in anticipation for a person to improperly perform their function or if the request, agreement to accept or acceptance of the bribe itself constitutes or is believed to constitute the improper performance of an activity. In addition, offering a bribe to a foreign public official to induce that public official to obtain or retain

business or an advantage in the conduct of business (and that is not permitted by local laws), will also be an offence.

3. Responsibilities

The prevention, detection and reporting of bribery and other forms of corruption is the responsibility of all those working for us, or supplying services to us, or under our control.

4. Gifts and Hospitality

4.1 Pi Healthcare permits normal and appropriate corporate entertainment, gifts, hospitality and promotional expenditure (given and received) to or from third parties that is undertaken:

a) for the purpose of establishing and maintaining good business relationships

b) to improve the image and reputation of Pi Healthcare

c) to present Pi Healthcare’s goods/services effectively

Provided that it is: a) in good faith b) not offered, promised or accepted to secure an advantage for its employees or associated persons or to influence the impartiality of the recipient

4.2 The giving of gifts by Pi Healthcare employees with an approximate value of £50 or higher (or the local equivalent outside the UK) is prohibited unless they have been given prior approval by their Head of Department. With regard to our employees receiving gifts, unless approval has been provided by the appropriate Head of Department, gifts that exceed a £50 threshold must be declined and will be recorded. Gifts in the form of cash must never be accepted by our employees or service providers and therefore must not be offered and any offers of cash must be immediately reported to the relevant Pi Healthcare Management Committee member. The giving or receiving of promotional material is not considered a gift.

4.3 The giving and receiving of corporate entertainment and hospitality for our employees should not exceed an approximate value of £50 per head (or the local equivalent outside the UK) without prior approval by a Pi Healthcare Management Committee member where possible and reasonable to do so in the circumstances.

4.4 The test to be applied is whether in all the circumstances, the gift, entertainment or hospitality is reasonable and justifiable. We expect the intention behind the gift to always be considered.

5. What is not acceptable?  

There are many scenarios where there will be a breach of the Bribery Act 2010, however below are some non-exhaustive scenarios as to we think is not acceptable for employees or service providers of Pi Healthcare to do, namely:

a) give, promise to give, or offer, a payment, gift or hospitality to a third party with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;

b) 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;

c) give, offer or promise to a foreign public official to induce that public official to obtain or retain business or an advantage in the conduct of business (and that is not permitted by local laws), request, agrees to receive or accept payment from a third party knowing or suspecting it is offered with the expectation that it will obtain a business advantage for them;

d) request, agrees to receive or accept payment from a third party knowing or suspecting it is offered with the expectation that it will obtain a business advantage for them;

e) accept a gift or hospitality from a third party knowing or suspecting that it is offered or provided with an expectation that a business advantage will be provided by Pi Healthcare in return ;

f) threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; and

g) engage in any activity that might lead to a breach of this policy

6. Facilitation payments and kickbacks

6.1 We and our service providers should not make, and should 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. Kickbacks are typically payments made in return for a business favour or advantage. We expect all employees and service providers must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.

6.2 If you are asked to make a payment on behalf of Pi Healthcare, 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.

6.3 Any transactions in contracts and documentation must be recorded so that there is never any attempt to hide the way a contract will work.

7. Record Keeping

7.1 We and our service providers are expected to keep financial records and have appropriate internal controls in place which will evidence the business reason for giving and/or receiving payments from/to third parties.

8. Raising Concerns  

8.1 If you believe this policy has been breached, or suspect it may have been breached, in any way please contact Pi Healthcare ([email protected])

By navigating this site, you agree to the storing of cookies on your device to enhance solely site navigation and analysis. In no way do we capture, store or sell personal information. View our Privacy Policy for more information.