Creo Pharma Limited Web Site Legal Notices and Terms
This is an important section of the Site and sets out the terms and conditions that apply to use of this Site by you. For the purposes of these Terms, “we”, “us” or “our” means Creo Pharma Limited; “you” or “your” means the visitor to or user of this Site. You may print out and keep a copy of the Terms. The Terms are a legal agreement and may only be modified with our consent. We reserve the right to change the Terms and any such changes will be posted here; any such changes will take effect immediately upon posting, whether you have reviewed them or not. By using this Site you are agreeing to the Terms; if you do not agree with any of these Terms you should cease using this Site immediately.
While the Site is intended for residents of the United Kingdom, its terms and conditions apply to all users.
A. GENERAL TERMS1. Copyright
All rights reserved. Material on this Site (including without limitation content, software, photographs, sounds, text, graphs, forms, graphics, ideas, articles, reports, notes and articles) is subject to copyright, database and other intellectual property rights unless otherwise indicated. The material may be downloaded to file or printer for personal and non-commercial use only without requiring specific prior consent provided that any copy that you make retains all trademark, copyright or other proprietary notices, and any disclaimer contained thereon and no documents or related graphics on the Site are modified in any way or used separately from the corresponding text.
No permission is required to establish hypertext links to this Site.
You acknowledge that you do not acquire any ownership rights by downloading any copyright material. The consent to use and reproduce any material does not extend to altering or deleting any copyright or trademark notices or to using any material on this Site that is identified as the copyright of a third party and authorisation to reproduce such material must be obtained from the copyright holders concerned. Any other proposed use of the material (including, without limitation, commercial exploitation, redistribution or publication) is subject to our prior written consent.
You may not modify, publish, transmit, participate in the transfer or sale, create derivative works or in any way exploit any material on the Site except as provided in the Terms.
All logos, product and brand names referred to herein are tradenames or trademarks of Creo Pharma Limited, its licensors, clients, customers, partners or suppliers. None of the trademarks, tradenames, product or brand names or logos may be used in any advertising or other publicity material in relation to the distribution of any information or material obtained from the Site without prior written consent. For further information or enquiries on trademarks contact.
2. Terms and Conditions of Use2.1 Use of the Site
We reserve the right to temporarily or permanently discontinue the Site at any time.
We endeavour to ensure that the Site is available for use 24 hours a day but we cannot guarantee it will always be so and we do not accept any liability for any non-availability. Access to the Site may be suspended temporarily and without notice in the case of system failure, maintenance or repair or for reasons beyond our control. You should retain details of our telephone and facsimile numbers for direct contact. The Site or access to the Site may be terminated permanently and without notice in our absolute discretion for operational or any other reason whatsoever.
We do not warrant that your use or access to the Site will be uninterrupted or error or virus free.
If we make any software owned or operated by a third party available to you, you must use this software in accordance with the terms and conditions imposed by the third party.
Hypertext links or resources to any other websites are provided solely for your convenience. We have not reviewed these websites or resources and are not responsible for their contents or availability. If you use these links or resources, you leave the Site. We do not endorse and are not responsible or liable for any content, advertising information, products, services or other materials on or available from such links or resources. We do not endorse or make any representations about them, or any material or information found there, or any results that may be obtained from using them. If you decide to access any websites or resources linked to the Site, you do so entirely at your own risk.
You undertake not to use the Site for any unlawful or prohibited purpose or in any manner that could damage, disable or overburden this Site or interfere with any other person’s use and enjoyment of it.2.2 Accuracy of Information and Disclaimer
We will use reasonable endeavours to ensure that all information and material on the Site is accurate and if you find anything that is inaccurate let us know and we will correct it as soon as practicable. However, due to the number of sources from which we obtain content and the nature of electronic distribution via the World Wide Web, we are making the Site available on an “as is” basis and make no representations that the information or material is accurate or up to date or complete and we accept no liability for any loss or damage caused by inaccurate information or material. We do not necessarily endorse nor are we responsible for the accuracy of or reliability of any opinion, advice or statement made on the Site. The information or material on the Site may be out of date, and we make no commitment to update it.
The information on the Site is not intended to address your particular requirements.
Accordingly, to the maximum extent permitted by law, we provide you with the Site on the basis that we exclude all representations, warranties, conditions and other terms (including, without limitation, the conditions implied by law of satisfactory quality, fitness for purpose and the use of reasonable care and skill) which, but for this legal notice, might have effect in relation to the Site.2.3 Our and Your Liability
We, any other party involved in creating, producing, maintaining or delivering the Site, and its partners, officers, directors, employees, and agents of any of them, exclude all liability and responsibility for any amount or kind of loss or damage that may result to you or a third party (including without limitation, any direct, indirect, punitive or consequential loss or damages, or any loss of income, profits, goodwill, data, contracts, use of money, or loss or damages arising from or connected in any way to business interruption, and whether in tort (including without limitation negligence), contract or otherwise) in connection with the Site in any way or in connection with the use, inability to use or the results of use of the Site, any websites or resources linked to the Site or the material on such websites or resources, including but not limited to loss or damage due to viruses, worms, Trojan horses or other destructive items, corrupted data or incompatible data that may infect your computer equipment, software, data or other property on account of your access to, use of, or browsing the Site or your downloading of any material or information from the Site or any websites or resources linked to the Site.
You will indemnify and hold us harmless against all loss and liability arising from claims made or litigation brought against us as a result of your use of the Site or its contents.
Nothing in these Terms shall operate to limit to exclude our liability for death or personal injury caused by our negligence or responsibility for fraudulent misrepresentations that cannot under English law be excluded.2.4 Barring from the Site
We reserve the right to bar users from the Site on a permanent or temporary basis at our discretion.2.5 Privacy and Use of Information
We control the Site from the United Kingdom and we make no warranty that the Site or any material or information on it or use or processing by us of personal information from you complies with any laws other than those of England. If you access the Site from anywhere other than the United Kingdom you must ensure compliance with local laws.
English law shall apply to the Terms notwithstanding any other jurisdiction where you are or access the Site. You irrevocably agree that the courts of England shall have the exclusive jurisdiction to settle any dispute that may arise in connection with the Terms and you submit to the exclusive jurisdiction of such courts.
All communications connected with the Site must be in English.
The Site is owned and operated by Creo Pharma Limited a company incorporated in England with registration number 6082846 and its registered office is at Felsted Business Centre, Cock Green, Felsted, Essex CM6 3 LY.
VAT registration number is 891578375.
Purpose of the Notice
This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act (1998 or 2018) and other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (Data Protection Legislation)
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
We are committed to ensuring that your privacy is protected and this policy sets out how Creo Pharma Limited intends to collect and use any personal information on the Site obtained from or about you if you use the facility on the Site to contact us. For the purposes of this Policy “we”, “us” or “ours” means Creo Pharma Limited; “you” or “yours” means the visitor to or user of this Site.
By using the site you are agreeing to the terms of this Policy. This Policy sets out how we intend to collect and use any personal information on the Site.
How we may collect your personal data
We obtain personal data from you, for example when:
- you contact us by telephone or in writing.
- you request a proposal from us in response of the services we provide.
- you email us regarding our products/services.
The reason for us collecting this information is for legitimate business purposes.
The kind of information we hold about you
The information we hold about you may include but is not limited to the following:
- your name and/or address
- your job title, employer and contact details
- our correspondence and communications with you.
- details of any services you have received from us.
- information about any complaints and enquiries you make to us.
How we use personal data we hold about you
We may process your personal data for purposes necessary for the performance of our contract with you OR your employer OR our customers and to comply with our legal obligations.
- To contact you to resolve any queries that you or us may have regarding us or the site or its use
- To respond to any queries or requests made by you
- In administration, general correspondence, support, profiling and processing incidental to the above
- To provide you with information, products and/or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes
- To carry out our obligations arising from any contracts entered into between you and us
- To notify you about changes to our services
- For staff training purposes, to help us to improve our services and to ensure the information we provide is consistent and accurate
- For reporting on the types and numbers of enquiries we receive
- To ensure that we have an accurate record of your call, which may be needed to support any transactions that take place
Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using you data.
Situations in which we will use your personal data
We may use your personal data in order to fulfil our legal obligations, such as but not limited to:
-Handling medical information enquiries about our products.
-Handling complaints regarding our products or service.
If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with your legal or regulatory obligations.
We may also process your personal data without your knowledge or consent in accordance with this notice, where we are legally required or permitted to do so.
How long we keep it for
We will keep your personal data for as long as is necessary to fulfil the purposes for which it is collected. When assessing what retention period is appropriate for your personal data, we take into consideration:
- the requirements of our business and the services provided
- any statutory or legal obligations
- the purpose for which we originally collected the personal data
- the lawful grounds on which we based our processing
- the types of personal data collected
- whether the purpose of the processing could reasonably be fulfilled by other means
Change of purpose
Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.
Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
We will share your personal data with third parties where we are required by the law, where necessary to administer the relationship between us or where we have another legitimate interest in doing so.
We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.
'Third parties' includes third- party service providers. The following activities are carried out by third- party services providers: e.g. IT and cloud services, banking services, Regulatory/Medical Information consultancies
All of our third- party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third party service providers to process your personal data for specified purposes and in accordance with our instructions.
Other non- personal information collected by us will be used to provide aggregate statistics in relation to pages being accessed and to monitor usage patterns on the Site in order to improve navigation and design features. This non- personal information may be aggregated and provided to third parties.
We will not share your data with third parties for marketing purposes unless we have procured your express consent to do so.
Transferring personal data outside the European Economic Union (EEA)
We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA.
For example, this might be required in order to provide our support services.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
We have put in place commercially reasonable and appropriate security measures to protect 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 data security breach and will notify you and any regulator of a suspected breach where we are legally required to do so.
Rights of access, corrections, erasure and restriction
It is important that the personal data that we hold about you is accurate and correct. Should your personal information change please notify us of any change of which we need to be made aware of by contacting us at email@example.com
You can choose to request access to your personal data.
You can request correction of the personal data that we hold about you
You can request erasure of the personal data that we hold about you
You can object to the processing of your personal data
You can request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible
You have the right to withdraw consent. To do this, please inform us at firstname.lastname@example.org
If you want to exercise any of the above rights or would like further information, please contact our data protection point of contact on email@example.com
Changes to this notice
Any changes that we make to our privacy notice in the future will be updated on our website http://www.creopharma.com/privacy.php
This policy was last updated on May 25th 2018.
If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email firstname.lastname@example.org
You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO's contact details are as follows:-
So that you can make full use of the interactive features on our website, your computer, mobile phone or other device (all referred to here as device) you will need to accept cookies.
Here you can see what cookies may be sent to your device by Creo Pharma Ltd and what we use each cookie for. You can set your browser to reject cookies (see the 'Help' menu of your browser to find out how to do this), but please bear in mind that if you do this, certain personalised features of this website cannot be provided to you.
What are Cookies?
Cookies’ are text files containing small amounts of information which are downloaded to your personal device when you visit a website. This information is then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user's device.
Cookies are used to maintain functionality on the Creo Pharma website
There are two types of cookies that can be used:
Persistent cookies - these cookies remain on a user's device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.
Session cookies - these cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.
Cookies used on this website
Strictly necessary cookies
These cookies enable services you have specifically asked for. These cookies will always be operating, regardless of consent.
These cookies are essential to enable you to move around the Website and use its features, such as accessing secure areas of the Website.
These cookies collect anonymous information on the pages visited. By using the Website, you agree that we can place these types of cookies on your device.
These cookies collect information about how visitors use the Website; for instance, which pages visitors go to most often, which pages they go to next and if they get error messages from web pages. These cookies don't collect information that identifies a visitor. All the information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the Website works.
These cookies remember choices you make to improve your experience. By using the Website, you agree that we can place these types of cookies on your device.
These cookies allow the Website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
A list of all the cookies used on our Website by category is set out below.
If you have any queries, please contact us at email@example.com
Anti Bribery & Corruption Policy
The UK Bribery Act 2010 (the “Act”) came into force on 1 July 2011. Under the Act, it is a criminal offence to offer or receive a bribe, to bribe a foreign public official or to fail to prevent bribery on Creo Pharma Ltd.’s behalf.
Our Anti Bribery and Corruption Policy below, which is also detailed in our Terms and Conditions already imposes obligations on both of us in relation to hospitality and gifts and we will consider failure by your company to comply with these obligations as a material breach of the terms of our trading agreement and would consequently terminate the agreement immediately. In view of the Act, we seek your co-operation to ensure full compliance with the Act. As part of Creo Pharma Ltd’s Company Manual, we also outline our internal Anti Bribery and Corruption Policy and Whistleblowing Policy.
Our Anti Bribery and Corruption Policy
It is the policy of Creo Pharma Ltd to conduct all of its business in an honest and ethical manner.
We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships and implementing and enforcing effective systems to counter bribery wherever we operate.
Creo Pharma Ltd and any persons providing services for or on our behalf (“Personnel”) shall not offer or receive any money, securities, goods or any other gifts to or from any individual employed by any of its customers, suppliers or trade partners for the purpose of inducing an undue advantage or other favorable business treatment, contrary to the principles of honesty and integrity.
Creo Pharma Ltd and its Personnel shall not provide any foreign or home public official with any money, security or goods for any improper or illegal purpose.
Creo Pharma Ltd and its Personnel will uphold all laws relevant to countering bribery and corruption, including the Bribery Act 2010, in all jurisdictions in which Creo Pharma Ltd operates.
Creo Pharma Ltd will cease trading immediately with any organisation, which engages in or which we have reasonable suspicion that it engages in bribery or other corrupt activity and, if appropriate, will report the matter to the relevant authorities.
Our Gifts and Entertainment Policy
The giving and receiving of gifts and entertainment can build understanding and expand relationships in everyday business life, but it can also cause conflict of interest between personal interests and professional duty.
This policy does not prohibit normal and appropriate hospitality (given and received) to and from third parties.
To avoid any misunderstanding or potential breaches of legislation, Creo Pharma Ltd is committed to a policy of transparent, proportionate, reasonable and bona fide hospitality and promotional expenditure. The acceptance or offer of any gift or entertainment regardless of value, that either makes the recipient feel obliged (or could be construed as a means to make the recipient feel obliged) to start or continue a business relationship, is unacceptable and will be a violation of our policy.
The giving and receiving of promotional items of nominal value or modest entertainment is acceptable where such hospitality is commensurate with the reasonable proportionate norms for the industry in which we operate. We appreciate the co-operation of our trading partners in respect of the above policies.
Our Whistle Blowing Policy. We are committed to conducting our business with honesty and integrity, and we expect all of our employees to maintain high standards in accordance with our Code of Ethical Conduct. We do, however recognise that all organisations face the risk of things going wrong from time to time, or of unknowingly harbouring illegal or unethical conduct. We believe that a culture of openness and accountability is essential in order to prevent such situations occurring or to address them when they do occur. We support sincere whistle blowers because uncovering any illegality or danger is in our company’s long-term interest.
Our Code of Ethical Conduct Policy. This policy is to remind all of our employees, regardless of their role, of our expectations and their duty to report any instance which falls below these expectations. We have a reputation for high ethical standards of corporate and personal behaviour with our clients, suppliers and other external agencies. This policy exists to make sure that everyone knows how we should act to maintain this.
Recruitment Policy. We only use specified, reputable employment agencies to source labour and always verify the practices of any new agency.
Awareness-Raising Updates. As well as providing our Modern Slavery Statement, we will raise awareness of modern slavery issues by circulating HR updates on any modern slavery and human trafficking topics.
Board/Member approval. This statement has been approved by Creo Pharma’s Board of Directors who will review and update it annually.
Modern Slavery Statement
This statement is made pursuant to section 54 (1) of the UK Modern Slavery Act 2015 and constitutes Creo Pharma’s slavery and human trafficking statement. It sets out the steps and plans to be taken by Creo Pharma to understand and mitigate modern slavery and human trafficking risks related to our business and to put in steps that are aimed at ensuring that there is no slavery or human trafficking in our business and supply chains.
Everyone has the absolute right not to be treated as a slave or made to perform forced or compulsory labour. Forced or compulsory labour under the act does not include:
- any work required to be done as part of a prison sentence or community punishment
- any type of military service
- any service required in the case of an emergency which could threaten the life or well-being of a community
- any work or service which forms part of normal civic obligations such as fire services.
We know that slavery, servitude, forced labour and human trafficking (Modern Slavery) is a global migration issue, existing in every region in the world and in every type of economy. No sector or industry can be considered immune or untainted. In 2016 the Global Slavery Index estimated that there were 8,300 people in modern slavery in the UK alone.
At Creo Pharma Ltd we pride ourselves on saying and doing everything with the highest ethical standards. We therefore also have a zero-tolerance approach to Modern Slavery or human trafficking of any kind within our operations and supply chains and we are currently in the process of trying to understand all potential modern slavery risks, however small they may be.
As part of the pharmaceutical industry, Creo Pharma Ltd recognises that we have a responsibility to take a robust approach to slavery and human trafficking. We are absolutely committed to preventing slavery and human trafficking in our corporate activities, and to ensuring that our supply chains are free from slavery and human trafficking.
Company Structure and Background
Creo Pharma Ltd is a UK based specialist pharmaceutical company dedicated to providing generic medicines, commercial brands and specialist supply products for the pharmacy, hospital and wholesale sector. We became part of Zentiva in April 2019 enabling us to further enhance our pharmaceuticals and generics capabilities for the benefit of our customers. Our annual turnover is circa £26M.
Our Supply Chains
We are supplied from more than 15 countries around the world but predominantly from Europe.
During this financial year we will conduct a risk assessment of the risk of modern slavery in the supply chain of Creo manufactured products and products manufactured on our behalf. We will assess whether or not particular activities or countries are high risk in relation to slavery or human trafficking. Based upon the results of this assessment, where appropriate, we will develop any required risk-based monitoring or assurance programme and this will be endorsed by our Supply Chain Manager with support as required from Human Resources and our Quality Department.
Current Anti-Slavery initiatives
- Policies. An HR Consultant has the responsibility for putting in place and reviewing policies. Our suite of policies is developed between HR, our Managers and signed off at Director Level. We also ask our employees to comment on the policies and feedback any views that they have.
- Risk assessments. We will carry out risk assessments to ensure that we have robust processes in place to manage any areas of risk to our employees and to our business. As we are supplied from other countries, it is crucial that we take responsibility for identifying any risks concerning human rights and modern slavery.
- Investigations/due diligence. We understand that our biggest exposure to Modern Slavery would be in our product supply chains. All manufacturers supplying Creo products, going forward, must complete a questionnaire prior to the Company doing business with them (and where relevant, enter into a formal supply contract). The supplier is required to provide information with regards to the steps they are taking to ensure that their Company is slavery free and provide information with regards to their policies and procedures to support their commitment to the Modern Slavery Act 2015.
- Training and Awareness. The Human Resources department will take responsibility for ensuring that all employees are aware of the Company’s statement of compliance with the Modern Slavery Act 2015 through this Modern Slavery Statement and with on-going commitment of this statement. All employees will sign to accept understanding of the statement and it will be available for all on our Company website and internal Company Policies and Procedures folder within our Company shared drive.
Training will be given to employees and management who have direct responsibility for supply chain management, particularly with respect to mitigation of risks within the supply chain.
Creo Pharma Ltd operates the above policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations.