Clause 22 - Meetings, Hospitality and Sponsorship
22.1 Companies must not provide hospitality to members of the health professions and other relevant decision makers except in association with scientific meetings, promotional meetings, scientific congresses and other such meetings, and training. Meetings must be held in appropriate venues conducive to the main purpose of the event. Hospitality must be strictly limited to the main purpose of the event and must be secondary to the purpose of the meeting ie subsistence only. The level of subsistence offered must be appropriate and not out of proportion to the occasion. The costs involved must not exceed that level which the recipients would normally adopt when paying for themselves. It must not extend beyond members of the health professions or other relevant decision makers.
The provision of hospitality is limited to refreshments/subsistence (meals and drinks), accommodation, genuine registration fees and the payment of reasonable travel costs which a company may provide to sponsor a delegate to attend a meeting. The payment of travel expenses and the like for persons accompanying the delegate is not permitted. Funding must not be offered or provided to compensate merely for the time spent by health professionals in attending meetings. The payment of reasonable honoraria and reimbursement of out of pocket expenses, including travel, for speakers, advisory board members and the providers of other professional services, is permissible. The arrangements for meetings must comply with Clause 22.1 with regard to hospitality and venues.
Companies should only offer or provide economy air travel to delegates sponsored to attend meetings. Delegates may organise and pay at their own expense the genuine cost of an upgrade. For flights that are scheduled to take longer than six hours companies may pay for an upgrade from economy to premium economy or similar.
Pharmaceutical companies may appropriately hold or sponsor a wide range of meetings. These range from small lunchtime audio-visual presentations in a group practice, hospital meetings and meetings at postgraduate education centres, advisory board meetings, visits to research and manufacturing facilites, planning, training and investigator meetings for clinical trials and non-interventional studies, launch meetings for new products, management training courses, patient support group meetings and satellite symposia through to large international meetings organised by independent bodies with sponsorship from pharmaceutical companies.
With any meeting, certain basic principles apply:
- the meeting must have a clear educational content
- the venue must be appropriate and conducive to the main purpose of the meeting; lavish, extravagant or deluxe venues must not be used, companies must not sponsor or organise entertainment (such as sporting or leisure events) and companies should avoid using venues that are renowned for their entertainment facilities
- the subsistence associated with the meeting must be secondary to the nature of the meeting, must be appropriate and not out of proportion to the occasion
- any hospitality provided must not extend to a spouse or other such person unless that person is a health professional or other relevant decision maker and qualifies as a proper delegate or participant at the meeting in their own right
- spouses and other accompanying persons, unless qualified as above, may not attend the actual meeting and may not receive any associated hospitality at the company’s expense; the entire costs which their presence involves are the responsibility of those they accompany.
Administrative staff may be invited to meetings where appropriate. For example, receptionists might be invited to a meeting in a general practice when the subject matter related to practice administration.
A useful criterion in determining whether the arrangements for any meeting are acceptable is to apply the question ‘would you and your company be willing to have these arrangements generally known?’ The impression that is created by the arrangements for any meeting must always be kept in mind.
Meetings organised for groups of doctors, other health professionals and/or for other relevant decsion makers etc. which are wholly or mainly of a social or sporting nature are unacceptable.
Meetings organised by pharmaceutical companies which involve UK health professionals at venues outside the UK are not necessarily unacceptable. There have, however, to be valid and cogent reasons for holding meetings at such venues. These are that most of the invitees are from outside the UK and, given their countries of origin, it makes greater logistical sense to hold the meeting outside the UK or, given the location of the relevant resource or expertise that is the object or subject matter of the meeting, it makes greater logistical sense to hold the meeting outside the UK. As with meetings held in the UK, in determining whether such a meeting is acceptable or not, consideration must also be given to the educational programme, overall cost, facilities offered by the venue, nature of the audience, subsistence provided and the like. As with any meeting it should be the programme that attracts delegates and not the associated hospitality or venue.
Promotional material which is displayed or provided at international meetings held outside the UK may, unless prohibited or otherwise regulated by local laws and regulations, refer to medicines or their indications which are not registered in the country where the event takes place, or which are registered under different conditions, so long as any such material is accompanied by a suitable statement indicating countries where the product is registered and making clear that the product is not registered locally. Any such promotional material which refers to the prescribing information authorized in a country or countries where the medicine is registered must be accompanied by an explanatory statement indicating that registration conditions differ internationally.
The requirements relating to international meetings held in the UK are set out in the supplementary information to Clause 3.
The requirements of the Code do not apply to the provision of hospitality other than to that referred to in Clauses 22.1 and 27.2 and the supplementary information to Clauses 23 and 26.2.
- Clause 22.1 Meetings Organised by Affiliates Outside the UK
- Clause 22.1 Certification of Meetings
- Clause 22.1 Health Professionals’ Codes of Conduct
- Clause 22.1 Continuing Professional Development (CPD) Meetings and Courses
MOST RECENT CASES See all Applicable Code year
22.2 The cost of a meal (including drinks) provided by way of subsistence must not exceed £75 per person, excluding VAT and gratuities.
22.3 Payments may not be made to doctors or groups of doctors or to other prescribers, either directly or indirectly, for rental for rooms to be used for meetings.
22.4 When meetings are sponsored by pharmaceutical companies, that fact must be disclosed in all of the papers relating to the meetings and in any published proceedings. The declaration of sponsorship must be sufficiently prominent to ensure that readers are aware of it at the outset.
22.5 Pharmaceutical companies must publicly disclose financial details of sponsorship of UK health professionals and other relevant decision makers in relation to attendance at meetings. Sponsorship in this context includes registration fees and the costs of accommodation and travel, both inside and outside the UK