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.
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22.2 The cost of a meal (including drinks) provided by way of subsistence must not exceed £75 per person, excluding VAT and gratuities.
22.3 Payments may not be made to doctors or groups of doctors or to other prescribers, either directly or indirectly, for rental for rooms to be used for meetings.
22.4 When meetings are sponsored by pharmaceutical companies, that fact must be disclosed in all of the papers relating to the meetings and in any published proceedings. The declaration of sponsorship must be sufficiently prominent to ensure that readers are aware of it at the outset.
22.5 Pharmaceutical companies must publicly disclose financial details of sponsorship of UK health professionals and other relevant decision makers in relation to attendance at meetings. Sponsorship in this context includes registration fees and the costs of accommodation and travel, both inside and outside the UK.
Clause 22.1 Meetings and Hospitality
The provision of hospitality is limited to refreshments/ subsistence (meals and drinks), accommodation, genuine registration fees and the payment of reasonable travel costs which a company may provide to sponsor a delegate to attend a meeting. The payment of travel expenses and the like for persons accompanying the delegate is not permitted. Funding must not be offered or provided to compensate merely for the time spent by health professionals in attending meetings. The payment of reasonable honoraria and reimbursement of out of pocket expenses, including travel, for speakers, advisory board members and the providers of other professional services, is permissible. The arrangements for meetings must comply with Clause
22.1 with regard to hospitality and venues. Companies should only offer or provide economy air travel to delegates sponsored to attend 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. Pharmaceutical companies may appropriately hold or sponsor a wide range of meetings. These range from small lunchtime audio-visual presentations in a group practice, hospital meetings and 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 meetings for new products, management training courses, patient support group meetings and satellite symposia through to large international meetings organised by independent bodies with sponsorship from pharmaceutical companies. With any meeting, certain basic principles apply:
Clause 22.1 Meetings Organised by Affiliates Outside the UK
Companies should remind their affiliates outside the UK that the ABPI Code of Practice must be complied with if UK health professionals attend meetings which they organise regardless of whether such meetings occur in the UK or abroad.
Clause 22.1 Certification of Meetings
Pharmaceutical companies must ensure that all meetings which are planned are checked to see that they comply with the Code. Companies must have a written document that sets out their policies on meetings and hospitality and the associated allowable expenditure. In addition, meetings which involve travel outside the UK must be formally certified as set out in Clause
Clause 22.1 Health Professionals’ Codes of Conduct
The General Medical Council 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 of conduct, ethics and performance state ‘Do not ask for or accept gifts, rewards or hospitality that may affect, or be seen to affect, your professional judgement’. The Code of the Nursing & Midwifery Council, Standards of conduct, performance and ethics for nurses and midwives, states ‘You must not abuse your privileged position for your own ends’ and ‘You must ensure that your professional judgement is not influenced by any commercial considerations’.
Clause 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 continuing professional development (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.
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Clause 22.2 Maximum Cost of a Meal
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 a meal (including drinks) should normally be well below this figure. The requirements relating to hospitality in Clause
22.1 and its supplementary information still apply. The maximum of £75 plus VAT and gratuities (or local equivalent) does not apply when a meeting is held outside the UK in a European country where the national association is a member of EFPIA and thus covered by EFPIA Codes. In such circumstances the limits in the host country code would apply. Information can be found at
Clause 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 22.4 Sponsorship and Reports of Meetings
Attention is drawn to Clause
9.10 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 that company. It should be noted that where companies are involved in the sponsorship and/or distribution of reports on meetings or symposia etc, these reports may constitute promotional material and thus be fully subject to the requirements of the Code.
Clause 22.5 Sponsorship of Attendance
Disclosure of this information must be carried out in accordance with Clause
24. Meetings at which attendance is sponsored by companies must also comply with Clause
22.1. The information required by Clause
22.5 must be publicly disclosed in respect of sponsorship for attendance at meetings held in 2015 and each calendar year thereafter. 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 cost of the sponsorship of that recipient must be given. 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.
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