Makro respects individual privacy and values the confidence of its customers, employees, clinical trial participants, business partners and others. Not only does Makro strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices. This Safe Harbor Privacy Policy (the “Policy”) sets forth the privacy principles that Makro follows with respect to transfers of personal information from the European Union (EU) to the United States.

SAFE HARBOUR
The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (the “Safe Harbor Principles”) to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EU to the United States. Consistent with its commitment to protect personal privacy, Makro adheres to the Safe Harbor Principles.

SCOPE
This Safe Harbor Privacy Policy (the "Policy") applies to all personal information received by Makro in the United States from the EU, in any format including electronic, paper or verbal.

DEFINITIONS
For purposes of this Policy, the following definitions shall apply:

"Agent" means any third party that uses personal information provided to Makro to perform tasks on behalf of and under the instructions of Makro.

"Makro" means Makro, its successors, subsidiaries, divisions and groups in the United States.

"Personal information" means any information or set of information that identifies or could be used by or on behalf of Makro to identify an individual. Personal information does not include information that is encoded or anonymized or publicly available information that has not been combined with non-public personal information.

"Sensitive personal information" means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. In addition, Makro will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

PRIVACY PRINCIPLES
The privacy principles in this Policy are based on the Safe Harbor Principles.

NOTICE:
Where Makro collects personal information directly from individuals in the EU, it will inform them about the purposes for which it collects and uses personal information about them, the types of non-agent third parties to which Makro discloses that information, and the choices and means, if any, Makro offers individuals for limiting the use and disclosure of their personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Makro, or as soon as practicable thereafter, and in any event before Makro uses the information for a purpose other than that for which it was originally collected.

Where Makro receives personal information from its subsidiaries, affiliates or other entities in the EU, it will use such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

CHOICE:
Makro will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

For sensitive personal information, Makro will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. Makro will provide individuals with reasonable mechanisms to exercise their choices.

DATA INTEGRITY:
Makro will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Makro will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

TRANSFERS TO AGENTS:
Makro will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Where Makro has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Makro will take reasonable steps to prevent or stop the use or disclosure.

ACCESS AND CORRECTION:
Upon request, Makro will grant individuals reasonable access to personal information that it holds about them. In addition, Makro will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

SECURITY:
Makro will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

ENFORCEMENT:
Makro will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Makro determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

DISPUTE RESOLUTION:
Any questions or concerns regarding the use or disclosure of personal information should be directed to the Makro Privacy Office at the address given below. Makro will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between Makro and the complainant, Makro has agreed to participate in the dispute resolution procedures of the panel established by the European data protection authorities to resolve disputes pursuant to the Safe Harbor Principles.

CONTACT INFORMATION
Questions or comments regarding this Policy should be submitted to the Makro Privacy Office by mail or e-mail as follows:

Makro Privacy Office
One Washington Park, Suite 1502
Newark, NJ 07102