Are individuals representing patient organisations' considered to be members of the public?

The arrangements for such services should meet the requirements of Clause 24.

Disclosure must be in the first six months in the calendar year following that in which the payments were made. The information which must be disclosed is the total amount paid in a calendar year to the public, including individual patients, journalists and members of the public who have provided services. The total number of individuals must be given. The names of the individuals need not be disclosed. Companies may, of course, give greater detail, for example, by giving separate figures for different categories of service or by providing details of the maximum and minimum payments etc.

A template to disclose the information required in relation to the public etc is available from the PMCPA website www.pmcpa.org.uk. The use of this template is optional.

All reasonable steps should be taken by companies to similarly disclose their best estimates of fees paid to UK individuals by overseas affiliates, head offices in the UK or overseas and UK-based European offices.

Companies must ensure that they have appropriate arrangements in place to lawfully disclose information about transfers of value and that recipients are aware of the process for disclosure.

Disclosure is required even if the payments etc are made by overseas affiliates, head offices in the UK or overseas and UK-based offices.