Clause 10.1 (22.1) Events/Meetings and Hospitality
In determining whether any event/meeting is acceptable or not, consideration must also be given to the educational programme, overall cost, facilities offered by the venue, nature of the audience, subsistence provided and the like.
Clause 10.1 (22.1) Types of Events/Meetings
Events/meetings range from small lunchtime audiovisual presentations in a group practice; hospital meetings and events/meetings at postgraduate education centres; advisory board meetings; visits to research and manufacturing facilities; planning, training and investigator meetings for clinical trials and non-interventional studies; launch events/meetings for new products; management training courses; patient support group meetings; and satellite symposia through to large international events/meetings organised by independent bodies with sponsorship from pharmaceutical companies.
The hospitality costs involved in events/meetings must not exceed that level which the recipients would normally adopt when paying for themselves.
Companies should only offer or provide economy air travel to delegates attending events/meetings. Delegates may organise and pay at their own expense the genuine cost of an upgrade. For flights that are scheduled to take longer than six hours, companies may pay for an upgrade from economy to premium economy or similar.
Administrative staff may be invited to events/meetings where appropriate. For example, receptionists might be invited to an event/meeting in a general practice when the subject matter is related to practice administration.
A useful criterion in determining whether the arrangements for any event/meeting are acceptable is to apply the question ‘Would you and your company be willing to have these arrangements generally known?’ The impression that is created by the arrangements for any event/meeting must always be kept in mind.
Clause 10.1 (22.1) Events/Meetings held Outside the UK
Events/meetings organised by pharmaceutical companies which involve UK health professionals at venues outside the UK are not necessarily unacceptable. There have, however, to be valid and cogent reasons for holding the event/meeting at such venues. These are that most of the invitees are from outside the UK and, given their countries of origin, it makes greater logistical sense to hold the event/meeting outside the UK or, given the location of the relevant resource or expertise that is the object or subject matter of the event/meeting, it makes greater logistical sense to hold the event/meeting outside the UK. Consideration should be given to the use of technology to avoid travel outside the UK, eg webinars, virtual meetings.
Clause 10.1 (22.1) Events/Meetings Organised by Affiliates Outside the UK
Companies should remind their affiliates outside the UK that the ABPI Code must be complied with if UK health professionals attend events/meetings which they organise, regardless of whether such events/meetings occur in the UK or abroad.
Clause 10.1 (22.1) Certification and Examination of Events/Meetings
Pharmaceutical companies must ensure that all events/meetings which are planned are examined to see that they comply with the Code. Companies must have a written document that sets out their policies on events/meetings and hospitality and the associated allowable expenditure. In addition, events/meetings which involve travel outside the UK must be certified as set out in Clause 8.2.
Clause 10.1 (22.1) Health Professionals’ Standards of Conduct
The General Medical Council (GMC) is the regulatory body for doctors and is responsible for giving guidance on standards of professional conduct and on medical ethics. In its guidance, the GMC advises that ‘You must not allow any interests you may have to affect the way you prescribe for, treat, refer or commission services for patients’ and ‘You must not ask for or accept from patients, colleagues or others any inducement, gift or hospitality that may affect or be seen to affect the way you prescribe for, treat or refer patients or commission services for patients. You must not offer these inducements’.
The General Pharmaceutical Council is the regulatory body for pharmacists and pharmacy technicians. The Council’s Standards for pharmacy professionals includes that they must use their professional judgement and must behave in a professional manner. They are expected to ‘declare any personal or professional interests and manage these professionally’.
The Code of the Nursing & Midwifery Council, Professional standards of practice and behaviour for nurses and midwives, states ‘You must act with honesty and integrity in any financial dealings you have with everyone you have a professional relationship with, including people in your care’.
In a joint statement, the chief executives of statutory regulators of health and care professionals (which refers to individuals regulated by one of nine regulators overseen by the Professional Standards Authority, including those referred to above) expect health and social care professionals to ‘Ensure their professional judgement is not compromised by personal, financial or commercial interests, incentives, targets or similar measures’ and to ‘Refuse all but the most trivial gifts, favours or hospitality, if accepting them could be interpreted as an attempt to gain preferential treatment or would contravene your professional code of practice’.
Clause 10.1 (22.1) Continuing Professional Development (CPD) Meetings and Courses
The provisions of this and all other relevant clauses in the Code apply equally to meetings and courses organised or sponsored by pharmaceutical companies which are CPD approved. The fact that a meeting or course has CPD approval does not mean that the arrangements are automatically acceptable under the Code. The relevant provisions of the Code and, in particular, those relating to hospitality, must be observed.
Clause 10.4 (18.3) Pens/Pencils and Notepads
Pens/pencils and notepads are the only items that can be provided to health professionals and other relevant decision makers for them to keep and then only at bona fide meetings. They cannot be provided, for example, by representatives when calling upon health professionals.
Clause 10.7 (22.2) Maximum Cost of Subsistence
The maximum of £75 plus VAT and gratuities is appropriate only in very exceptional circumstances, such as a dinner at a residential meeting for senior consultants or a dinner at a learned society conference with substantial educational content. The cost of subsistence (food and drink) should normally be well below this figure. The requirements relating to hospitality in Clause 10.1 and its supplementary information still apply.
The maximum of £75 plus VAT and gratuities (or local equivalent) does not apply when an event/meeting is held outside the UK in a European country where the national association is a member of EFPIA and thus covered by the EFPIA Code. In such circumstances, the limits in the host country code would apply. Information can be found at www.efpia.eu.
Clause 10.8 (22.3) Payment of Room Rental
This provision does not preclude the payment of room rental to postgraduate medical centres and the like.
Payment of room rental to doctors or groups of doctors or to other prescribers is not permissible even if such payment is made to equipment funds or patients’ comforts funds and the like or to charities or companies.
Clause 10.9 (22.4) Sponsorship and Reports of Events/Meetings
Attention is drawn to Clause 5.5 which requires that all material relating to medicines and their uses, whether promotional or not, which is sponsored by a pharmaceutical company must clearly indicate that it has been sponsored by the company.
Where companies are involved in the sponsorship and/or distribution of reports on events/meetings or symposia, etc these reports may constitute promotional material and thus be fully subject to the requirements of the Code.
Clause 10.10 (22.5) Support of Individual Health Professionals/Other Relevant Decision Makers to attend Events/Meetings
Disclosure of this information must be carried out in accordance with Clause 28.
The information required by Clause 10.10 must be publicly disclosed annually in respect of support for attendance at events/meetings whether paid directly, indirectly or via another party. Support in this context includes registration fees and the costs of accommodation and travel, both inside and outside the UK.
The information which must be disclosed comprises registration fees and the costs of accommodation and travel, both inside and outside the UK. The name of each recipient and the associated transfer of value for that recipient must be given.
Where a transfer of value is made to a health professional or other relevant decision maker indirectly via a healthcare organisation, institution or other party, such a transfer should be disclosed once only, preferably as being a transfer to the health professional or other relevant decision maker.
Clause 10.11 (New) Sponsorship to Healthcare Organisations, Institutions and Other Organisations
Disclosure of this information must be carried out in accordance with Clause 28.
Sponsorship in this context includes registration fees and the costs of accommodation and travel, both inside and outside the UK, whether paid directly or indirectly. If, when providing sponsorship to a healthcare organisation, institution or other organisation in relation to their own event, a company contributes towards the overall cost of subsistence (food and drink), then this must be included in the disclosure of the cost of the sponsorship to the healthcare organisation, institution or other organisation.
The Code allows the provision of hospitality at scientific meetings, promotional meetings, training and the like and there is no reason why this should not be offered from an exhibition stand. Obviously companies would have to be certain that the hospitality overall complied with the Code and that any hospitality provided from an exhibition stand was subsistence only and not at a level such as to induce a delegate to visit the stand.
In the PMCPA's view companies should provide no more than non-alcoholic beverages, such as tea, coffee and water, and very limited quantities of sweets, biscuits or fruit. The PMCPA does not consider that hot dogs, ice-cream, yoghurt, waffles, etc should be provided at exhibition stands.