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United Kingdom
transparency obligations overview

Latest update: 13 March 2019 | Important Notes
PHARMACUETICAL
MEDICAL DEVICE

Pharmaceutical Companies

What is reported:

  • Joint working
  • Donations, grants and benefits
  • Contracts between companies and institutions, organizations and associations
  • Sponsorship of attendance by HCPs and other relevant decision makers at meetings
  • Fees and expenses paid to HCPs and other relevant decision makers, or to their employers on their behalf
  • Contributions towards the costs of meetings paid to HCOs or to third parties managing events on their behalf, which may include sponsorship of HCPs by way of registration fees and accommodation and travel

Meals are not included.

Medical Device Companies

ABHI carried out a complete transposition of the MedTech Europe Code.

The ABHI Code is an exact transposition of the MTE Code, with the exception of the addition of sections on advertising and promotional activities, complaints, and Sponsored Posts.

ABHI has also included four new annexes relating to the MedTech Conference Vetting System (CVS) and the Disclosure of Education Grants on the MTE platform.

What is reported:

According to the ABHI Code, Educational Grants will be documented and publicly disclosed by member companies to ensure increased transparency of the funds allocated to medical education.

ABHI has elected to use the MedTech Europe platform for grant disclosures.

The ABHI Code added 2 Annexes to further clarify the disclosure guidelines, including an example methodology note.

Important notes:
  • This information is provided for your convenience and should not be construed as legal advice. The applicability of these requirements to your organization depends on individual circumstances. The information is not exhaustive.
  • Kindly check with your legal department and do not depend solely on the information provided here. Moreover, the rules mentioned could be subject to interpretation of local authorities/courts in the applicable jurisdiction. Lastly, be mindful of the latest update mentioned above. These rules and regulations change frequently, so it is important to determine whether the information provided reflects the most recent changes and is still applicable.
  • Reporting dates are related to the transparency obligation regarding transfers of value by pharmaceutical companies and/or medical device companies (excluding suppliers of in vitro diagnostics) to HCPs and HCOs. These often are based on laws or rules in codes of conduct of industry associations. In case it is based on codes of conduct, your company only needs to disclose the transfers of value on the mentioned due date if your company is a member of the association that follows that code.
  • Including a jurisdiction in the Legislative Watch does not guarantee that jurisdiction is available for reporting via the MediSpend Transparency Reporting Solution.
  • Reporting date normally means the date the transfers of value need to be published. The deadline for e.g. submission/sending the complete information to the authority could be before that date, for example to give HCPs and/or HCOs and/or the authority/association who publishes the information, the possibility to check the data the pharmaceutical companies/medical device companies are going to disclose.
  • The information does not take into consideration (unless explicitly mentioned):
    • Transparency related to clinical trials (unless it concerns transfers of value as mentioned above)
    • Transparency related to patient organizations (unless the patient organization is considered an HCO)


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