When completing the Disclosure template what should pharmaceutical companies include in the 'total' column?

  • 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.


This is made clear in the template for disclosing 2018 data onwards, which is available to download here