What are the relevant requirements for meetings when UK health professionals/other relevant decision makers are supported by pharmaceutical companies as delegates to a meeting outside the UK not organised by a pharmaceutical company?

  • 14.2

    14.2 All meetings involving travel outside the UK, unless the company’s only involvement is to support a speaker to present at the meeting, must be certified in advance by an appropriately qualified person. That person does not need to be either a registered medical practitioner or a UK registered pharmacist.

  • 22.1

    ​​22.1 Companies must not provide hospitality to members of the health professions and other relevant decision makers except in association with scientific meetings, promotional meetings, scientific congresses and other such meetings, and training. Meetings must be held in appropriate venues conducive to the main purpose of the event. Hospitality must be strictly limited to the main purpose of the event and must be secondary to the purpose of the meeting ie subsistence only. The level of subsistence offered must be appropriate and not out of proportion to the occasion. The costs involved must not exceed that level which the recipients would normally adopt when paying for themselves. It must not extend beyond members of the health professions or other relevant decision makers.

  • 24

    Clause 24 - Transfers of Value to Health Professionals and Healthcare Organisations

    24.1 Companies must document and publicly disclose certain transfers of value made directly or indirectly to health professionals and healthcare organisations located in Europe.

    The term ‘transfer of value’ is defined in Clause 1.10. The term ‘Europe’ comprises those countries that are within the EU and other countries with a trade association that is a member of EFPIA. 

    The term ‘health professional’ in relation to disclosure of transfers of value also includes any employee of a pharmaceutical company whose primary occupation is that of a practising health professional as defined in Clause 1.4.

    Disclosure is required even if the payments etc are made by overseas affiliates, head offices in the UK or overseas and UK based offices.

    24.2 The transfers of value covered by Clause 24.1 are

    • joint working in accordance with Clause 20
    • donations, grants and benefits in kind provided to institutions, organisations and associations in accordance with Clauses 19.1 and 19.2
    • contracts between companies and institutions, organisations and associations in accordance with Clause 21
    • sponsorship of attendance by health professionals and other relevant decision makers at meetings in accordance with Clause 22.5
    • fees and expenses paid to health professionals and other relevant decision makers, or to their employers on their behalf, in accordance with Clauses 23.2, 23.3 and 23.4
    • contributions towards the costs of meetings paid to healthcare organisations or to third parties managing events on their behalf, which may include sponsorship of health professionals by way of registration fees and accommodation and travel.

    Supplementary information Clause 24.2 Further Information

    24.3  Clause 24.1 does not apply to transfers of value to patient organisations. These transfers of value are covered by Clauses 27.7 and 27.8.

    24.4 Disclosures must be made annually in respect of each calendar year. Disclosure must be in the first six months after the end of the calendar year in which the transfers of value were made.

    24.5 The information disclosed must remain in the public domain for at least three years from the time of disclosure.

    24.6 Companies must document all disclosures and retain the records for at least five years after the end of the calendar year to which they relate.

    24.7 Different categories of transfers of value to individual health professionals can be aggregated on a category by category basis, provided that itemised disclosure would be made available upon request to the relevant recipient or the relevant authorities.

    Payments to healthcare organisations are required to be disclosed on a per activity basis.

    24.8 Where a transfer of value is made to a health professional indirectly via a healthcare organisation such a transfer should be disclosed once only, preferably as being a transfer to the health professional.

    24.9 Where recipients of transfers of value cannot be identified for legal reasons, the amount attributable to such transfers must be disclosed on an aggregate basis. The number of recipients involved must be stated together with the percentage of all recipients that they represent and the aggregate amount attributable to transfers of value to such recipients.

    24.10 Each company providing transfers of value must publish a note summarising the methodologies used by it in preparing the disclosures and identifying each category of transfer of value. The note, including a general summary and/or country specific considerations, must describe the recognition methodologies applied and should include the treatment of multi-year contracts, VAT and other tax aspects, currency aspects and other issues relating to the timing and amount of transfers of value for the purposes of this Code.


Before sending a UK health professional/other relevant decision maker to a meeting outside the UK companies should ensure the meeting itself meets the requirements of Clause 22.1 and its supplementary information.

Clause 14.2 applies: companies must certify all meetings which involve travel outside the UK in advance, this should be carried out by an appropriately qualified person.

Clause 24 in relation to disclosure of transfers of value will also need to be followed where relevant. Also refer to Clause 3.1 supplementary information