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.
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Clause 24.1 Transfers of Value
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.
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Clause 24.1 Consent to Disclosure
Companies are encouraged to include in a contract involving a transfer of value provisions regarding the consent of the recipient to its disclosure. In addition, companies are encouraged to renegotiate existing contracts at their earliest convenience to include such consent to disclosure. Companies must ensure that they have appropriate arrangements in place to lawfully disclose information about transfers of value.
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Clause 24.1 Mode of Disclosure
There will be a central platform for disclosure in the UK which companies must use. The template to be used is available from the Authority’s website www.pmcpa.org.uk.
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Clause 24.1 Date of Implementation
The information required by Clause 24.1 must be disclosed in respect of transfers of value made in 2015 and each calendar year thereafter.
most recent cases
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Applicable Code year
Applicable Code year
Please check the date of the Code that applies to the Case that you are looking at. The date of the complaint may vary from the activity/material alleged to have been in breach.
AUTH/3876/2/24 - Complainants v Novo Nordisk
Breach: 24.1, 24.4, 24.7, 24.1, 24.4, 27.7, 24.1, 24.4, 27.7, 2, 5.1, 28.1, 29.1, 29.2, 31.1
No breach: 24.1, 27.7, 24.1, 24.4, 27.7, 24.1, 24.4, 24.5, 27.7, 28.1, 29.1, 29.2, 31.1, 31.2
Applicable Code:
2021
Received: 02 February 2024
Completed: 25 October 2024
AUTH/3141/12/18 - Health Professional v Merck Sharp & Dohme
Breach: 7.2, 24.1
No breach: 2, 9.1
Applicable Code:
2016
Received: 21 December 2018
Completed: 15 November 2019
AUTH/3138/12/18 - Ex-employee v Indivior
Breach: 2, 9.1, 24.1, 24.4
No breach: 24.6
Applicable Code:
2016
Received: 20 December 2018
Completed: 19 August 2019
AUTH/3140/12/18 - Health professional v Amgen
Breach: 7.2, 9.1, 24.1
No breach: 7.2, 9.1, 2, 24.1
Applicable Code:
2016
Received: 21 December 2018
Completed: 10 August 2019
AUTH/2883/10/16 - Voluntary admission by Astellas UK
Patient support programmes
Breach: 2, 7.2, 7.9, 7.11, 9.1, 14.3, 14.5, 21, 24.1
No breach: 2, 9.1, 14.1, 26.1
Applicable Code:
2016
Received: 18 October 2016
Completed: 22 May 2019
AUTH/3418/11/20 - Pharmaceutical physician v Leo Pharma
Breach: 9.1, 13.1, 27.7
No breach: 2, 9.1, 14.3, 14.5, 20, 24.1, 24.9, 26.3, 27.7, 28.6
Applicable Code:
2019
Received: 11 November 2020
Completed: 18 November 2021
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.
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Clause 24.2 Further Information
The clauses of the Code noted in Clause 24.2 should be consulted for further information about the requirements. In addition, the requirements of Clauses 22.1 and 22.5 should be borne in mind in relation to sponsorship of meetings.
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.
most recent cases
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Applicable Code year
Applicable Code year
Please check the date of the Code that applies to the Case that you are looking at. The date of the complaint may vary from the activity/material alleged to have been in breach.
AUTH/3876/2/24 - Complainants v Novo Nordisk
Breach: 24.1, 24.4, 24.7, 24.1, 24.4, 27.7, 24.1, 24.4, 27.7, 2, 5.1, 28.1, 29.1, 29.2, 31.1
No breach: 24.1, 27.7, 24.1, 24.4, 27.7, 24.1, 24.4, 24.5, 27.7, 28.1, 29.1, 29.2, 31.1, 31.2
Applicable Code:
2021
Received: 02 February 2024
Completed: 25 October 2024
AUTH/3138/12/18 - Ex-employee v Indivior
Breach: 2, 9.1, 24.1, 24.4
No breach: 24.6
Applicable Code:
2016
Received: 20 December 2018
Completed: 19 August 2019
AUTH/2975/9/17 - Voluntary admission by A Menarini
Late disclosure of research and development payments
Breach: 24.4
Applicable Code:
2016
Received: 30 August 2017
Completed: 16 January 2018
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.
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Applicable Code year
Applicable Code year
Please check the date of the Code that applies to the Case that you are looking at. The date of the complaint may vary from the activity/material alleged to have been in breach.
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.
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Clause 24.9 Disclosure of Transfers of Value to Individuals
If an individual health professional or other relevant decision maker receives a number of transfers of value from a company and decides not to agree to disclosure of one or more of those transfers of value, then that company can disclose all of that individual’s transfers of value in its aggregate amount.
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.
