What should pharmaceutical companies do if a healthcare professional wishes to disclose some, but not all, transfers of value against their name?

The purpose of disclosure is to bring greater transparency to the relationships the pharmaceutical industry has with, amongst others, health professionals, other relevant decision makers and healthcare organisations. It is therefore desirable for companies to publish as fully as possible, details of transfers of value at a named, individual level where they are lawfully able to do so.

Clause 28.5 and its supplementary information allows for companies to operate an 'all in' or 'all out' policy with regards to individuals who wish to disclose only some of the transfers of value they receive from a company.

Companies should make it clear in their methodological note the number of individuals who have agreed to some payments being disclosed individually and some in aggregate.