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Disclosure Code

Methodology note

Methodology Note regarding the implementation of the EFPIA Disclosure Code, locally transposed by the Transparency Code Employers’ Union of Innovative Pharmaceutical Companies INFARMA (ZPIFF INFARMA).

We at Bayer are convinced that close cooperation with and continuous education of healthcare professionals is key to achieving better outcomes for the patients we strive to help. We are committed to transparency regarding how healthcare professionals (HCP) and healthcare organizations (HCO) are compensated by us for the time and expertise they provide. When collaborating with medical experts, we comply with applicable laws and regulations such as the EFPIA Disclosure Code in Europe and various local legal reporting obligations and fully respect the independence and integrity of these professionals. The EFPIA Disclosure Code has been locally transposed by the Transparency Code Employers’ Union of Innovative Pharmaceutical Companies INFARMA (“Transparency Code”). These codes are designed to ensure that even the impression of potential conflicts of interest are avoided. By making the cooperation between the industry and the medical community more transparent, the general public can gain a better understanding of the high importance and value of this cooperation.

 

In order to make the nature and the extent of the interaction between the pharmaceutical industry and HCPs and organizations more transparent, Bayer will document and disclose all Transfers of Value (ToV) in scope of the Transparency Code which it makes, directly or indirectly, to the benefit of a HCPs or HCOs. The reporting period is always a full calendar year. 

 

The purpose of this methodology note is to allow any person accessing the report to understand how Bayer is documenting and disclosing the relevant information. It shall especially explain the details of the data collection and reporting methodology. The general rules of the Transparency Code apply to all member companies and all companies will disclose relevant Transfers of Value in a pre-defined format. However, some details of the reporting methodology are left for the individual companies to decide in order to allow the necessary flexibility to adjust to the internal processes.

 

If in doubt about the duty to disclose a specific Transfer of Value, our company will always aim for full disclosure. Only if a Transfer of Value is clearly out of scope of the Transparency Code it will not be included in the published report.

 

This methodology note is structured as follows: Based on a specific question, we will explain in detail, how Bayer handles disclosure of Transfers of Value to HCPs and HCOs. The general explanation will – where possible – also be illustrated by examples to ensure a clear understanding.

 

Find out how we document and disclose transfer of value provided to healthcare professionals. Click here for the local Methodology Note.

Data Privacy

General questions

Questions on the report