What the EFPIA Disclosure Code Is About
Bayer fully supports greater transparency in the relationship between the pharmaceutical industry and healthcare professionals and organizations and therefore ensures compliance with the EFPIA Disclosure Code
40 Leading European Companies in 33 Countries are Committed to the EFPIA Disclosure Code
The EFPIA Disclosure Code (full title: EFPIA Disclosure Code of Transfers of Value from Pharmaceutical Companies to Healthcare Professionals and Healthcare Organizations) is a voluntary commitment that requires all EFPIA member companies to disclose transfers of value to healthcare professionals and healthcare organizations. Under this code, all EFPIA member companies, including Bayer, will publish all direct and indirect, monetary and non-monetary transfers of value related to the development and commercialization of prescription-only human pharmaceuticals. Disclosure of payments (or transfer of value) made in the previous calendar year will be published at the latest by the end of June of the current year. This process will be repeated every year.
Level of Compensation
Healthcare professionals are compensated for their expertise and the services they provide to the pharmaceutical industry. The level of payments and transfers of value depend on the kind of activity, level of expertise, and amount of time. The permissible amounts depend on various factors, e.g. local income level, governing laws and existing codes. The core principle is fair market value remuneration for services received to ensure that honoraria are not misused to unduly influence healthcare professionals in their treatment decisions
Individual or Aggregated Disclosure?
Transfers of value to healthcare professionals will be reported on an individual or an aggregated basis. As the EFPIA Disclosure Code is an industry self-obligation, data privacy laws in most European countries allow individual disclosure only with explicit consent from the healthcare professional. In others there might be a legal obligation or legitimate interest in reporting payments individually. Should a healthcare professional not grant his/her consent for individual disclosure, then transfers of value to such a healthcare professional will be reported on an aggregated basis. In some countries, consent must also be obtained from healthcare organizations. Transfers of value in the area of ‘Research and Development’ will always be reported on an aggregated level as regulated by the EFPIA Disclosure Code.
Data Privacy
Bayer fully respects data privacy and data security. We therefore take multiple steps to protect data in compliance with the data privacy policies required and audited by local and global authorities. Furthermore, data are disclosed only if the affected healthcare professional has provided explicit written consent in those countries where it is legally required. High data security mechanisms are in place to ensure data are protected against external attacks and manipulation. In addition, access to any personal disclosure related data is restricted internally to employees responsible for data collection or report preparation.
Full Disclosure
We believe that only complete disclosure provides a fair picture of our relationship to a healthcare professional, and therefore will not disclose any partial data at the individual level. Any disagreement to disclose a specific activity is treated by Bayer as general dissent regarding disclosure. Instead, all transfers of value will be reported on an aggregated basis within the EFPIA reporting template.
The disclosed data include transfers of value in four main categories
Categories | Transfers of value | |
|---|---|---|
Healthcare Professionals | Healthcare Organizations | |
Donations and grants | Whether monetary or other | |
Events |
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Services and consultancy |
| |
Research and development | Fees, travel & accommodation, and other related expenses that are covered in connection with the service | |
We at Bayer confirm that our disclosures of transfers of value (ToVs) to HCPs and HCOs have been reported in application of the EFPIA Disclosure Code key principles.
Get Access to the National Data Disclosure
According to the EFPIA Disclosure Code payments, in the majority of countries in Europe, are disclosed on Bayer company global and local websites. In that case links accessible from the list above will be leading directly to the respective country’s data disclosure report available in English and local language.
In other countries, due to the either existing national legislation or legislation in development and country self-regulation, often in partnership with stakeholders, disclosure is required on a central online platform. In that case above links will be leading to the respective country’s disclosure section on the Bayer company local webpage enabling further information.