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 (HCPs) and healthcare organizations (HCOs) 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 code compliance of the local association/SfEE and the Greek Legislation (art.66, par.7a, L.4316/2014 FEK A270/24.12.2014These 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 healthcare professionals and organizations more transparent, Bayer will document and disclose all Transfers of Value in scope of the EFPIA Disclosure Code & local regulations which it makes, directly or indirectly, to the benefit of a HCPs or HCOs. The reporting period is always a full calendar year. The first report, published in 2016, will cover all relevant Transfers of Value made in 2015.
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 EFPIA Disclosure Code apply to all member companies and all companies will disclose relevant Transfers of Value in a pre-defined format. Similarly local legislation on Dislcosure mandates all Greek pharma companies to disclose their relevant TOVs. 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 Disclosure Code or local legislation, 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. In addition, the following importnat note should be read.
Important note: In accordance with the EFPIA/SfEE Disclosure Code and the local legislation for disclosure, Bayer Hellas discloses transfers of value to Healthcare Professionals and Healthcare Organizations connected to the development and commercialization of prescription-only human pharmaceuticals.
Bayer Hellas is in full readiness to proceed to disclosure according to the above.
Following the publication of the legal opinion 5/2016 of the Data Protection Authority for the content of which we became aware only this day 30.06.2016, we disclose hereunder in an aggregated way the transfers of value to Healthcare Professionals and individually the respective transfers of value to Healthcare Organizations.
We express our reservation as regards the updated disclosure awaiting final guidance from the involved authorities.