Sub-Agent Certification Process

The Sub-Agent Certification Process is a critical step in ensuring that all sub-agents working under MicroPharma Authorized Agents fully understand the legal and ethical responsibilities associated with selling peptides for research purposes only. Sub-agents are directly connected to the primary agent's business operations, meaning their compliance with regulatory guidelines is essential to avoid potential legal liabilities.

The Importance of Training Sub-Agents

Agents are not only responsible for their own compliance but also for the behavior and actions of their sub-agents. If a sub-agent violates any agreements or breaches compliance, it can have serious consequences for the primary agent. This could lead to the termination of the agent’s contract with MicroPharma or, worse, legal liabilities. Therefore, agents must ensure that sub-agents are properly trained and adhere to all regulatory and company guidelines.

Agents should think of themselves as trainers for their sub-agents. It is their responsibility to communicate the following key concepts to sub-agents:

• Legal Compliance: Ensure that sub-agents fully understand the FDA, DEA, and USADA regulations. This includes strict adherence to marketing peptides for research and development purposes only and avoiding any health claims or suggestions of human use.

• Avoiding Health Claims: Sub-agents must be instructed on how to avoid making health claims or dosage recommendations, and instead use appropriate language such as “In research settings, researchers have done XYZ.”

• Marketing and Sales Practices: Sub-agents must follow MicroPharma’s approved marketing materials and only use language that stays within the legal framework. Agents should stress the importance of using the liability waiver in conversations where clients push the boundaries of peptide use.

Step 1: Training Provided by the Agent

The primary agent is responsible for providing comprehensive training to the sub-agent. This training should cover all aspects of compliance, including:

• FDA, DEA, and USADA regulations: Sub-agents need to understand the legal boundaries of selling peptides for research purposes and how to communicate those boundaries to clients.

• Product Knowledge: Sub-agents must be knowledgeable about the peptides, their research uses, and how to avoid promoting them for therapeutic purposes.

• Sales Techniques: Ensure sub-agents know how to handle objections and guide conversations in ways that do not violate FDA or company policies, using language such as “Some researchers have explored XYZ in controlled settings.”

Step 2: Signing the Sub-Agent Agreement

You should make them sign a Sub-Agent Agreement, which outlines the terms of their relationship with MicroPharma and the primary agent. The agreement includes:

• Non-compete clauses: Sub-agents must agree not to promote or sell competing products.

• Liability clauses: Sub-agents acknowledge the importance of compliance and that failure to comply could result in legal liability for both the sub-agent and the primary agent.

Step 3: Ongoing Monitoring and Compliance

Agents must monitor their sub-agents regularly to ensure ongoing compliance. Any deviations from legal or ethical standards could not only result in the sub-agent being removed but could also impact the primary agent’s standing with MicroPharma. Ongoing monitoring includes:

• Regular check-ins: Ensure sub-agents are following proper sales practices.

• Reviewing communications: Periodically review how sub-agents are interacting with clients to make sure they are using the correct language and waivers.

Agent’s Legal Responsibility

Agents must understand that they are ultimately responsible for the actions of their sub-agents. If a sub-agent breaks compliance, it can sever the agent’s contract with MicroPharma, and the agent could face legal liability for any damages resulting from the sub-agent’s actions. Therefore, it is imperative to treat the training and management of sub-agents as a core responsibility of their business operations.

By carefully overseeing the sub-agent certification process and maintaining strict compliance, agents protect their business and their relationship with MicroPharma.