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. The first disclosures related to payments made in 2015 will be made by June 2016, at the latest. This disclosure process will be repeated for each reporting period in the subsequent years.
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. 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.
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. 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.
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.