EGA Code of Conduct

EUROPEAN generic medicines association
patients
Quality
value
sustainability
partnership
EGA
Code of Conduct on Interactions
with the Healthcare Community
Version 2 | Adopted by the EGA General Assembly on 8 December 2015
Including Transparency Rules and Requirements for Disclosure Chapter

EGA | EUROPEAN GENERIC MEDICINES ASSOCIATION
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T: +32 (0) 2 736 84 11 | F: +32 (0) 2 736 74 38
www.egagenerics.com | info@egagenerics.com
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EGA Code of Conduct on Interactions with the Healthcare Community
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Published by EGA - European Generic medicines Association
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EUROPEAN generic medicines association 3
EGA Code of Conduct on Interactions with the Healthcare Community1 february 2015
Updated in January 2016
Contents
1. Introduction and Purpose..............................................................................................................................................................................................................................................................................................................................................................................................................................................3
2. Preamble..............................................................................................................................................................................................................................................................................................................................................................................................................................................................................................3
3. Applicability of EGA Code...............................................................................................................................................................................................................................................................................................................................................................................................................................................4
4. Guidelines...........................................................................................................................................................................................................................................................................................................................................................................................................................................................................................5
4.1. Patients and Patient Organisations...............................................................................................................................................................................................................................................................................................................................................................................................5
4.2. Fee for Service and Consultancy......................................................................................................................................................................................................................................................................................................................................................................................................7
4.3. Meetings and Hospitality..........................................................................................................................................................................................................................................................................................................................................................................................................................8
4.4. Educational Support for Healthcare Professionals......................................................................................................................................................................................................................................................................................................................................................9
4.5. Site Visits.......................................................................................................................................................................................................................................................................................................................................................................................................................................................................9
4.6. Sponsorship of Events.............................................................................................................................................................................................................................................................................................................................................................................................................................. 10
4.7. Social Contributions................................................................................................................................................................................................................................................................................................................................................................................................................................... 10
4.8. Educational Materials, Medical Utility Items and Inexpensive Gifts................................................................................................................................................................................................................................................................................................... 10
4.9. Samples..................................................................................................................................................................................................................................................................................................................................................................................................................................................................... 11
4.10. Promotional Materials and Information........................................................................................................................................................................................................................................................................................................................................................................... 11
4.11. Transparency.................................................................................................................................................................................................................................................................................................................................................................................................................................................... 12
4.12. Data Protection............................................................................................................................................................................................................................................................................................................................................................................................................................................. 12
5. Enforcement Procedures.............................................................................................................................................................................................................................................................................................................................................................................................................................................. 13
6. Definitions...................................................................................................................................................................................................................................................................................................................................................................................................................................................................................... 14
7. Transparency Rules and Requirements..................................................................................................................................................................................................................................................................................................................................................................................................... 16
7.1. Disclosing Transfers of Value............................................................................................................................................................................................................................................................................................................................................................................................................. 16
7.2. Company’s Methodological Note............................................................................................................................................................................................................................................................................................................................................................................................... 18
7.3. Data Privacy and Consent.................................................................................................................................................................................................................................................................................................................................................................................................................... 18
7.4. Platform for Disclosure............................................................................................................................................................................................................................................................................................................................................................................................................................ 18
7.5. Other Acceptable Forms of Disclosure............................................................................................................................................................................................................................................................................................................................................... 18
7.6. Implementation Period..................................................................................................................................................................................................................................................................................................................................................................................... 19
7.7. Frequency of Disclosing................................................................................................................................................................................................................................................................................................................................................................................... 19
1
EGA Code of Conduct on Interactions with the Healthcare Community, adopted by the EGA General Assembly on 9th
December 2014, Version 1, including Transparency Rules and Requirements for Disclosure Chapter Version 1 | December 2015

EUROPEAN generic medicines association4
EGA Code of Conduct on Interactions with the Healthcare Community adopted by the EGA General Assembly
on 9th
1. Introduction and Purpose
The EGA endorses the “List of Guiding Principles Promoting Good Governance in the
Pharmaceutical Sector” under the Corporate Social Responsibility Platform by the Euro-
pean Commission. In order to ensure good governance, interactions should be based on
fundamental principles of integrity, mutual respect, responsiveness, accountability, col-
laboration and transparency. The EGA Code also addresses core values of independence,
fair market value for services obtained, and up to date scientific documentation for inte-
ractions with Healthcare Professionals, Healthcare Organisations, Patients and Patient
Organisations. These values are defined in the Section on Definitions.
This EGA Code of Conduct on Interactions with the Healthcare Community (EGA Code)
aims to set a framework of standards and principles that promotes trust, responsible be-
haviour, and respect, between pharmaceutical companies and the Healthcare Commu-
nity, including Healthcare Professionals, Healthcare Organisations, patients and Patient
Organisations.
2. Preamble
The EGA is a non-profit, non-governmental organisation representing industry associa-
tions and companies from across Europe. EGA Members are committed to the ethical
standards set out in the EGA Code.
It is a requirement of EGA membership that EGA national associations accept the condi-
tions of the EGA Code and, subject to applicable rules and requirements, adopt codes
that meet both applicable rules and requirements and are consistent with, and at least as
comprehensive as, the EGA Code. The Code is intended to be a self-regulatory standard
and is without prejudice to any existing or future legislation.
The Code sets standards for pharmaceutical companies with regard to ethical interac-
tions with the Healthcare Community. The EGA Code is not intended to address or re-
gulate commercial terms and conditions relating to the price, sale and distribution of
medicines, which must always be in compliance with applicable rules and requirements.
The EGA member companies are accountable for addressing and correcting infringe-
ments under the EGA Code and/or the codes implemented by EGA national associations.
Companies that are not members of the EGA or its member associations may none-
theless follow the EGA Code and/or the codes implemented by EGA national associa-
tions.
The principles set forth in the EGA Code are mandatory and shall be implemented by all
EGA Members. However, where Applicable rules and requirements related to EGA Mem-
bers are more stringent than the principles in the EGA Code, those applicable rules and
requirements shall prevail.

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3. Applicability of EGA Code
The EGA Code only applies to prescription-only medicines.
The EGA Code applies to EGA Members including EGA Member Companies, EGA Mem-
ber Company Affiliates, EGA National Association Members and EGA National Associa-
tion Affiliate Members.
An EGA national association must either adopt the EGA Code, or a comparable code that
is at least as strict as the EGA Code, and make it formally applicable to its member com-
panies.
EGA member companies must directly apply the rules and requirements of the EGA
Code to their activities or apply rules and requirements that are consistent with, and at
least as comprehensive as, the rules and requirements of the EGA Code. The subsidiaries
of EGA member companies must either adopt the EGA Code or the code that has been
adopted by the EGA national association.
It is acknowledged that the business practices and business models of EGA Members
vary from country to country, due to regulatory, legal and market factors. Not all of the
provisions of the EGA Code are relevant to all companies in all countries, since certain
activities may not be undertaken. Nevertheless, the EGA Code applies in its entirety and
should be read in the spirit in which it is intended.
4. Guidelines
4.1. Patients and Patient Organisations
• Non-promotion of prescription-only medicines
EU and national legislation and codes of practice, prohibiting the advertising of prescrip-
tion-only medicines to the general public, apply.
• Written agreements
When companies provide financial support, significant indirect support and/or signifi-
cant non-financial support to Patient Organisations, they must have in place a written
agreement. This must state the amount of funding and also the purpose (e.g. unres-
tricted grant, specific meeting or publication, etc). If applicable, it must also include a
description of significant indirect support (e.g. the donation of public relations agency’s
time and the nature of its involvement) and significant non-financial support. Each com-
pany should have an approval process in place for these agreements.
• Use of logos and proprietary materials
The public use of a Patient Organisation’s logo and/or proprietary material by a compa-
ny requires written permission from that organisation. In seeking such permission, the
specific purpose and the way the logo and/or proprietary material will be used must be
clearly stated.
• Editorial Control
Companies must not seek to influence the text of Patient Organisation material they sup-
port in a manner favourable to their own commercial interests. This does not preclude
companies from correcting factual inaccuracies. In addition, at the request of Patient
Organisations, companies may contribute to the drafting of the text from a fair and ba-
lanced scientific perspective.

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• Transparency
Each company must make publicly available a list of Patient Organisations to which it
provides financial support and/or significant indirect/non-financial support. This should
include a description of the nature of the support that is sufficiently complete to enable
the average reader to form an understanding of the significance of the support. The des-
cription must include the monetary value of financial support and of invoiced costs.
For significant non-financial support that cannot be assigned a meaningful monetary
value the description must describe clearly the non-monetary benefit that the Patient
Organisation receives. This information may be provided on a national and/or European
level and should be updated at least once a year.
Companies must ensure that their sponsorship is always clearly acknowledged and ap-
parent from the outset.
Each company must make publicly available a list of Patient Organisations that it has
engaged to provide significant contracted services. This should include a description of
the nature of the services provided that is sufficiently complete to enable the average
reader to form an understanding of the nature of the arrangement without the necessity
to divulge confidential information. Companies must also make public the total amount
paid per Patient Organisation over the reporting period.
• Contracted Services
Contracts between companies and Patient Organisations under which they provide
any type of services to companies are only allowed if such services are provided for the
purpose of supporting healthcare or research. It is permitted to engage Patient Organi-
sations as experts and advisors for services such as participation at advisory board mee-
tings and speaker services. The arrangements that cover consultancy or other services
must, to the extent relevant to the particular arrangement, fulfil all the following criteria:
a) A written contract or agreement is agreed in advance which specifies the nature of
the services to be provided and, subject to clause (g) below, the basis for payment of
those services;
b) A legitimate need for the services has been clearly identified and documented in ad-
vance of requesting the services and entering into the arrangements;
c) The criteria for selecting services are directly related to the identified need and the
persons responsible for selecting the service have the expertise necessary to evaluate
whether the particular experts and advisors meet those criteria;
d) The extent of the service is not greater than is reasonably necessary to achieve the
identified need;
e) The contracting company maintains records concerning, and makes appropriate use
of, the services;
f) The engaging of Patient Organisations is not an inducement to recommend a particu-
lar medicinal product;
g) The compensation for the services is reasonable and does not exceed the Fair Market
Value of the services provided. In this regard, token consultancy arrangements must
not be used to justify compensating Patient Organisations;
h) In their written contracts with Patient Organisations, companies are strongly encou-
raged to include provisions regarding an obligation of the Patient Organisation to
declare that they have provided paid services to the company whenever they write or
speak in public about a matter that is the subject of the agreement or any other issue
relating to that company;
i) Each company must make publicly available a list of Patient Organisations that it has
engaged to provide paid-for services.
• Single company funding
No company may require that it be the sole funder of a Patient Organisation or any of its
major programmes.

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4.2. Fee for Service and Consultancy
The expert advice and support by Healthcare Professionals and Healthcare Organisations
are important to help companies make decisions and take actions that benefit the pa-
tients and the Healthcare Communities they serve.
Companies may engage Healthcare Professionals and Healthcare Organisations to pro-
vide necessary services, such as serving as experts on advisory boards, speaking enga-
gements, participating in research, participating in focus groups or market research,
training and educating on products.
In all cases, a company must have a legitimate need for the service, pay no more than
fair market value and retain only the appropriate number of Healthcare Professionals or
Healthcare Organisations necessary to effectively fulfil the service. Healthcare Professio-
nals must only be selected and engaged as service providers based on their qualifica-
tions, expertise and abilities to provide the service.
An engagement must not be offered or entered into with the intention to induce the
Healthcare Organisation or Healthcare Professional to supply, dispense, promote, pres-
cribe, approve, reimburse, purchase, or recommend a particular product, influence out-
comes of clinical trials, or otherwise improperly benefit business activities.
All engagements, regardless of extent, must be confirmed in writing or contract, with
a clear description of the services and the compensation. In addition, the consultant
should, whenever possible, be required to disclose the engagement to the consultant’s
employer.
Payment shall only be made for work performed.

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4.3. Meetings and Hospitality
Meetings between companies and Healthcare Professionals and Healthcare Organisa-
tions (to the extent that the participants from the Healthcare Organisations are Heal-
thcare Professionals) facilitate the beneficial and essential interactions amongst them.
Meetings may be held for educational, scientific or research purposes, and promotional
purposes. Reasonable hospitality may be provided in connection with such meetings.
Depending on the nature of the meeting, hospitality may include hotel accommoda-
tion, meals and drinks, and must always be necessary, incidental, reasonable, and secon-
dary to the main purpose of the meeting. Stand-alone hospitality or entertainment, not
connected to any work-related meeting, is prohibited.
• Location
A meeting should be held in a location that makes the most logistical sense in light of
the location of the attendees or resources necessary for the meeting. This could include
major transport hubs and cities with appropriate infrastructure. Locations primarily
known for their touristic or recreational character are prohibited.
• Venue
Venues must be appropriate and conducive to the main purpose of the meeting. Appro-
priate venues may include clinical, laboratory, educational, conference or healthcare set-
tings, or business locations such as business hotels or conference centres. Luxury hotels,
resorts, venues known for their entertainment or recreational value, or extravagant ve-
nues are never appropriate.

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• Hospitality
Companies may provide hotel accommodation, meals and drinks in connection with a
meeting, as long as such hospitality is necessary, incidental, reasonable, and secondary
to the main purpose of the meeting. Hospitality must not be lavish or luxurious, must be
reasonable and proportionate, and may only be extended to the persons who qualify as
participants in their own right.

• Travel
Travel should always be on the most direct and logical route, taking into account costs to
the company. Stop-overs, side trips and trip extensions funded or facilitated by a compa-
ny are prohibited. Arrival and departures should, whenever logistically possible, coincide
with the beginning and end of the meeting. Flights should be booked in economy class;
business class may only be compensated in exceptional circumstances, if justified.
4.4. Educational Support for Healthcare Professionals
Companies may support scientific, medical, pharmaceutical and professional education
in the communities they serve. By inviting and funding Healthcare Professionals to mee-
tings and conferences, companies contribute to the advancement of scientific knowle-
dge and the improvement of patient care.
A company may provide educational support by paying registration costs, travel and
accommodation and reasonable hospitality to support an individual Healthcare Profes-
sional to attend events that educate them in areas relevant to their field. Educational
support may be provided for company-organized events or for congresses and confe-
rences organized by third parties.
• Types of Meetings
Companies may sponsor Healthcare Professionals to attend company-organized mee-
tings, as well as recognized conferences and congresses, provided that the meetings
have material scientific, educational and professional content, are in therapeutic areas
in which the Healthcare Professional currently practices and are directly related to the
company’s therapeutic areas.
• Invitees
Appropriately qualified Healthcare Professionals may be invited to meetings and confe-
rences and receive hospitality and travel support. Guests, spouses, family members, or
friends of Healthcare Professionals may not be invited to meetings and conferences and
may not receive any hospitality or travel or anything else of value. A company cannot fa-
cilitate and should actively discourage the accompaniment of uninvited guests on com-
pany funded travel.
The decision about who shall receive educational support shall be based on objectively
defined criteria that are directly related to the educational needs of the recipient and the
educational value of the program.
4.5. Site Visits
Visiting and touring a company’s manufacturing and RD facilities helps Healthcare Pro-
fessionals to better understand the efficacy and quality of a company’s products and
operations. This assists in building understanding and faith in generic and biosimilar me-
dicines and supports the Healthcare Professional in making decisions for the benefit of
patients and the public.
Visits to a company’s facilities must have educational value and may never be provided
as a means of improperly influencing a Healthcare Professional. Healthcare Professionals
should only ever be taken to visit the most logistically logical site that can demonstrate
the core manufacturing capabilities or technology that is crucial to the educational ob-
jectives.

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All site visits must have a specific and full agenda. As a general matter, such visits should
be limited in duration to closely coincide with their purpose and may not include any
side trips, trip extensions, stop-overs or any recreation or entertainment. The arrival and
departure of participants should closely coincide with the start and finish of the meeting.
4.6. Sponsorship of Events
Subject to the Applicable rules and requirements, companies may provide financial
sponsorship to third-party organisations for meetings, events or projects directed at
Healthcare Professionals, provided the events are relevant to the company’s therapeutic
areas or business interests. In recognition of their support, they can receive commercial
advertising opportunities, booth or exhibit space, distribution of promotional material,
company branding of banners and materials, and similar acknowledgments
Before committing to sponsoring any event, companies should take care to understand
the nature of the event, the program content and any associated hospitality. Companies
must ascertain that the sponsored funds will only be used for the stated purpose.
Companies must not use sponsorship as a way to indirectly fund or support any acti-
vity that they could not legitimately undertake themselves. A company must not provide
sponsorship that funds or subsidises recreational or entertainment activities for Health-
care Professionals.
4.7. Social Contributions
As responsible corporate citizens, companies may contribute to the communities they
serve.
Contributions may be provided to recognized charities, civic organisations and not-for-
profit institutions, but never to natural persons or for-profit entities. Contributions can
take the form of financial and in-kind donations for the purpose of supporting scienti-
fic research, medical education, patient education, patient access to healthcare, and the
overall development of healthcare systems. A company may also support community
and charitable initiatives.
Contributions must be supported by an unsolicited and independent request from the
institution, including a detailed description of their needs, the program or project, and
the budget. Contributions, including details of the program or project, must be memo-
rialized in writing. This requirement may be deemed to be fulfilled where a company is
responding to a public appeal by a charity of national or international renown. A com-
pany must ensure it has a sufficient understanding of how the funds will be used.
Contributions to Healthcare Organisations must serve the purpose of supporting heal-
thcare goals, like research and education, and are documented and kept on record. They
must never be provided as a means of improperly influencing a Healthcare Professional
or Healthcare Organisation, and must not influence decisions on research programmes
and on persons benefitting from donations (unrestricted grants). With the exception of
legitimate research and/or educational grants, donations/grants to individual Healthcare
Professionals are not allowed. Unrestricted contributions to Healthcare Organisations
that are not tied to a specific project or activity are prohibited.
4.8. Educational Materials, Medical Utility Items and Inexpensive Gifts
Companies may occasionally provide educational materials, medical utility items and
inexpensive gifts to a Healthcare Professional in accordance with Applicable rules and
requirements.
All such items must be relevant to a Healthcare Professional’s professional duties and

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ultimately benefit patients, patient care or the practice of medicine or pharmacy. Such
items should never provide a personal benefit to a Healthcare Professional and must ne-
ver be provided as a means of improperly influencing the Healthcare Professional.
Gifts and medical utility items may not offset the costs of operating a Healthcare Profes-
sional’s practice. Therefore providing medical supplies that are normal and necessary for
the day-to-day practice of medicine (e.g. tongue depressors, latex gloves, etc.) are prohi-
bited. Items that could be easily resold or used to generate income are also prohibited.
Gifts must not be given in the form of cash or cash equivalents.
4.9. Samples
Samples of prescription-only medicinal products may only be provided on an exceptio-
nal basis to help Healthcare Professionals who are authorized to prescribe them to fami-
liarize themselves with certain products and acquire experience in dealing with them.
Samples cannot financially enrich a Healthcare Professional and cannot be re-sold by the
Healthcare Professional. Healthcare Professionals must be informed of this and the pac-
kaging must clearly indicate this.
Medical samples should only be given on an occasional basis, in line with applicable
legal limits on amounts and frequency, and only upon the prior written request of the
Healthcare Professional.
Companies must establish and maintain appropriate controls for distribution of samples.
4.10. Promotional Materials and Information
Companies may promote pharmaceutical products by providing relevant information to
healthcare professionals and assisting their decision-making.
Companies may not promote prescription medicines and products to patients, the pu-
blic or any other person that does not qualify as a Healthcare Professional. Companies
may promote their corporate brand, their company and the generic industry to the pu-
blic through normal advertising and promotional channels, to the extent permitted by
Applicable rules and requirements.
All promotional materials and information (whether printed, electronic or oral) must be
clear, legible, accurate, up-to-date, balanced, fair, and sufficiently complete to enable the
recipient to form his or her own opinion. It must not be misleading and must encourage

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the rational use of medicinal products by presenting them objectively and without exag-
geration.
Scientific promotional claims and comparisons must always be scientifically up-to-date,
referenced, clinically relevant and consistent with the licensed indication.“Off-label”pro-
motional messages are prohibited.
Companies must ensure that all materials and information are reviewed by competent
reviewers before they are disseminated or used. They must regularly review their mate-
rials to ensure they remain relevant and consistent with current available scientific know-
ledge. Companies must have procedures in place to withdraw outdated or superseded
materials and to prevent their further use.
Materials and information must comply with applicable rules and requirements in every
country in which they are used or disseminated.
4.11. Transparency
Promoting transparent relations or interactions between companies and Healthcare Pro-
fessionals/Organisations to relevant stakeholders assists informed decision-making and
helps to prevent unethical and illegal behaviour.
Under various applicable rules and requirements, companies must disclose engage-
ments, payments and other transfers of value to Healthcare Professionals and Healthcare
Organisations, either publicly or directly to specific stakeholders. Companies must there-
fore adhere to all applicable disclosure rules and requirements.
Companies should disclose engagements and transfers of value that could potentially
pose a conflict of interest or encourage the recipients of the transfers of value to disclose
them, where such disclosure would be in the best interest of patients or the public.
4.12. Data Protection
If processing personal data received from, collected about or concerning Healthcare Pro-
fessionals, Healthcare Organisations, Patients and Patient Organisations, applicable data
protection laws must be complied with.
Any disclosure must be compatible with data privacy legislation.

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5. Enforcement Procedures
EGA member companies are encouraged to report potential violations of the EGA Code.
EGA member companies should follow, in the first instance, the enforcement procedures
set forth by the relevant EGA national association. National associations should therefore
establish enforcement, complaint and appeal procedures, preferably by self-regulatory
mechanisms and if appropriate by additional co-regulatory mechanisms.
In the exceptional event that the EGA national association does not have adequate en-
forcement procedures, the following procedures apply. A national association may also
transfer a claim to the EGA Secretariat for adjudication.
Present enforcement procedure does not cause prejudice to nor limit the right of any
EGA Member to bring any matter at any time before competent jurisdictions or adminis-
trative authorities.
• Inter-company dialogue
If a company A believes a company B has violated the EGA Code, company A should re-
port such alleged violation to the company B. The two companies shall work to resolve
the matter between themselves, in good faith and in the spirit of the EGA Code. Inter-
company dialogue shall be confidential between the involved parties and limited to
what is necessary to discuss the alleged violation.
• Formal Complaint
If the companies cannot resolve the matter to their mutual satisfaction, either company
may report it to the EGA Secretariat. The company must file a detailed written complaint
at the EGA Secretariat. The EGA Secretariat shall send the complaint by registered letter
to the EGA Executives and to the company alleged to be in breach. Within 30 days fol-
lowing the date of the registered letter, the alleged breaching company shall respond to
this complaint in writing and per registered letter to the EGA Secretariat. The EGA Secreta-
riat shall communicate this reply to the Executives and the claimant per registered letter.
• Adjudication and Records
Upon receipt by the EGA Secretariat of a complaint, a review committee of 3 persons,
appointed by the EGA Executives, will be set-up to review the complaint and the reply.
The review committee shall be composed one EGA Secretariat member, one EGA natio-
nal association who has no conflicting interests with the parties involved in the matter
to be adjudicated and one external independent expert (arbitrator, lawyer). The review
committee may define specific rules of procedure, seek additional clarifications from the
parties involved, invite the company representatives to appear in-person, or contract ex-
ternal experts, as needed. The language of the procedure before the committee will be
English and, unless the parties involved and the review committee agree otherwise, the
location of the procedure will be Brussels. The procedure before the committee will be
suspended if a party to the procedure is pursuing a legal complaint before a court or an
administrative authority directly related to the case pending before the committee until
the final enforceable decision of the court or administrative authority.
• Findings and Sanctions
The review committee will issue its findings in writing and may make a recommenda-
tion or impose sanctions and/or remediation measures, in as far as and to the extent not
prohibited by the EGA Code. The decision of the committee is not open for appeal. The
companies involved in the procedure are bound by the decision of the committee for
the duration of their EGA membership and unless such decision is contradicted by an
order or decision of a competent administrative authority or court involving said compa-
nies. The companies commit to abide by the decision and to take the corrective actions
to immediately cease the breach concerned and implement the remedial measures to
avoid similar breaches of the Code in future. The EGA shall not have the power to levy

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fines or award damages. EGA Members may however expel, in accordance with EGA’s
bylaws and the applicable legislation, a company from the Association in egregious or
repetitive cases and in circumstances where the company’s activities have been such as
to potentially bring the pharmaceutical industry or the generics and biosimilars sector
into disrepute. The succumbing party will bear the costs related to the procedure before
the committee, including the costs of the experts contracted by the committee, if any.
Each party will however bear the costs of its own experts, counsels etc.
• Publication of Cases and Findings
Decisions of the committee will be published if agreed by both parties or, without their
agreement, upon decision of the committee if repetitive and/or (a) serious breach(es) of
the Code is/are concerned, on EGA and national relevant national association websites.
If, after the decision of the committee, a party to the procedure initiates a formal com-
plaint before a court or administrative authority directly related to the case, the publi-
cation of the committee’s decision will be delayed until the final enforceable decision
of the court or administrative authority. The names of the companies and their location
will be identified, but the identity of individual persons involved shall not be publicly dis-
closed. Confidential information will not be disclosed. The purpose of such publication
shall be to provide information and guidance about the EGA Code and its application
to companies and the public. EGA national associations shall also report breaches and
cases to the EGA for publication.
6. Definitions
• Applicable rules and requirements
All laws (including national laws), regulations, codes of practices and standards that ap-
ply to a company or transaction in any given location or circumstance.
• EGA Code
This EGA Code of Conduct on Interactions with the Healthcare Community.
• EGA Members
EGA member companies (including EGA member company affiliates) and EGA national
associations (including EGA national associations affiliate members).
• Healthcare Community
Healthcare Professionals, Healthcare Organisations, Patients and Patient Organisations.
• Healthcare Professional
Any natural person that is a doctor, a member of medical, dental, pharmacy or nursing
professions or any other person who, in the course of his or her professional activities,
may prescribe, purchase, supply, recommend or administer a medicinal product. For the
avoidance of doubt, the definition of Healthcare Professional includes: (i) any official or
employee of a government agency or other organisation (whether in the public or pri-
vate sector) that may prescribe, dispense, purchase or administer medicinal products
and (ii) any employee of a pharmaceutical company whose primary occupation is that
of a practising Healthcare Professional, but excludes (x) all other employees of a pharma-
ceutical company and (y) a wholesaler or distributor of medicinal products.
• Healthcare Organisation
Any entity (i) that is a healthcare, medical or scientific association or organisation (irres-

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pective of the legal or organisational form) such as a hospital, clinic, foundation, univer-
sity or other teaching institution or learned society or (ii) through which one or more
Healthcare Professionals provide healthcare services. For the avoidance of doubt, whole-
salers, distributors, and similar commercial intermediaries are not considered Healthcare
Organisations.
• Patient Organisations
Not-for-profit organisations which are patient-focused, and in which patients or their ca-
rers represent a majority of members in their governing bodies.
• Independence
Pharmaceutical companies must respect the independence of Healthcare Professionals
and not interfere with the relationship and trust that exists between patients and their
Healthcare Professionals.
• Transparency
Interaction between pharmaceutical companies and the Healthcare Community must be
transparent and comply with Applicable rules and requirements.
• Fair market value
Where members of the Healthcare Community are engaged to perform a service, or
where Sponsorship or contributions are provided, the remuneration and payments must
be fair market value. This is understood as the value that would be paid as a result of
bona fide bargaining between well-informed parties in arm’s-length transactions for the
goods or services to be provided. The value shall consider the nature or quality of the
goods or services to be provided, the qualifications and experience of the provider, the
geographic location where goods or services are to be provided, the nature of the mar-
ket for the goods or services to be provided, and the prevailing rates for similar goods or
services.
• Documentation
Pharmaceutical companies shall adequately document their interactions with the Heal-
thcare Community, by entering into contracts and written agreements, where appro-
priate, and keeping and maintaining appropriate records and evidence of activities and
engagements, such as copies of agreements, related reports, and invoices.

7. Transparency Rules and Requirements
7.1. Disclosing Transfers of Value
Transparent relations and interactions between companies and Healthcare Professio-
nals/Organisations and Patient Organisations assist informed decision-making and help
to prevent unethical and illegal behaviour. The EGA Code therefore requires EGA mem-
ber companies to disclose Transfers of Value that could potentially pose a conflict of inte-
rest, or to encourage the recipients of the transfers of value to disclose them, where such
disclosure would be in the best interest of patients or the public, further specified below.
Such disclosure shall include Transfers of Value made by a third party on behalf of an EGA
member company for the benefit of a recipient and where the EGA member company
knows or is informed about the recipient who will benefit from the Transfer of Value.
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A Transfer of Value can include anything of value that is provided (or “transferred”) by an
EGA member company (directly or indirectly via a third party acting at its direction) to a
recipient, including monetary payments or in-kind benefits, such as meals, travel, hospi-
tality, gifts, etc.
Each EGA member company shall disclose the amounts attributable to a Transfer of Va-
lue which can be reasonably allocated to one of the categories set out below. Transfers of
Value that are not listed below, do not need to be disclosed under this Code.
Transfers of Value shall be disclosed on an individual, named basis:
• Transfers of Value to Patient Organisations:
- Support: financial and in-kind support
- Fee for services: contracted services per Patient Organisation, including a des-
cription of the nature of the Transfer of Value (educational summer camp,
disease awareness world day, development of information brochures for an awa-
reness campaign, etc.) and the amount provided.
• Transfers of Value to Healthcare Professionals:
- Fees for services and consultancy: aggregated honoraria (excluding expenses
such as meals and drinks, travel and accommodation) paid by a Company to an
Healthcare Professional in exchange for the provision of services, such as serving
as an expert on an advisory board, speaking at a company-organised educatio-
nal event, participating in a focus group, etc. Fees paid in connection with re-
search development activities or market research, are excluded from the scope
of this disclosure.
- Meetings, educational support and site visits: EGA member companies have two
options for disclosure and may decide (for themselves and for their affiliates)
which option to adopt for disclosure in this category:

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• Total number (but not actual monetary value) of events, for which an individual
Healthcare Professional has received support (which may include payment of
registration fees, travel and/or hotel costs). Support shall be disclosed per individual
Healthcare Professional in the following categories and sub-categories:
- Sponsorship for attending a third party organised congress (as per section 4.4),
where the company pays for registration fees, travel or accommodation. Indicate
whether each event is local/domestic, within Europe or outside of Europe.
- Site visits (as per section 4.5).
- Company organised meetings for which a Healthcare Professional receives company
funded hotel accommodation and/or airplane travel (as per section 4.3).
Aggregate total amount of support provided to Healthcare Professionals per individual
conference or meeting as follows:
• Sponsorship for attending a third party organised congress (as per section 4.4):
- name of congress,
- aggregated amount spent for the congress, including the
- number of Healthcare Professionals financially supported to attend.
• Site visits (as per section 4.5): aggregated amount spent, including the number of
Healthcare Professionals financially supported to attend.
• Company organised meeting: aggregated amount spent, including the number of
Healthcare Professionals financially supported to attend.
OPTION 1
OPTION 2
• Transfers of Value to Healthcare Organisations:
- Fees for services and consultancy: aggregated honoraria (excluding expenses
such as meals and drinks, travel and accommodation) paid by a Company to an
Healthcare Organisation in exchange for the provision of services, such as serving
as an expert on an advisory board, speaking at a company-organised educational
event, participating in a focus group, etc. Fees paid in connection with research
development activities or market research, are excluded from the scope of this
disclosure.
- Grants and donations: aggregated monetary amounts and a brief description of the
nature of the grant or donation (e.g. research grant, equipment donation, product
donation, etc.)
7.2. Company’s Methodological Note
Along with its disclosure, each EGA member company shall publish a note summarising
the methodology which they have applied in preparing the disclosure and identifying
Transfers of Value for each category. This shall describe the recognition methodologies
and should include the treatment of multi-year contracts, VAT plus other tax aspects, cur-
rency aspects and other issues related to the timing and amount of Transfers of Value for
the purposes of this Code.
It is recommended to include VAT and any other taxes in the disclosure amount, as re-
quired by local laws and regulations. Where no rules are in place, the company should
decide on VAT disclosure.
EGA member companies are advised to disclose in Euro and in the local currency if requi-
red by the applicable law and regulations. Where the Euro is not the local currency, the
company should decide on the currency used for disclosure.

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7.3. Data Privacy and Consent
Each EGA member company will respect the applicable data privacy laws and regula-
tions. To the extent required and in compliance with applicable data privacy laws and
regulations, companies should seek the required consent from individual Healthcare
Professionals to publish Transfer of Value data regarding the individual Healthcare Pro-
fessional concerned.
If a Healthcare Professional refuses to provide the consent required under applicable
data privacy laws and regulations, the company concerned shall nonetheless publish
the Transfers of Value related to the Healthcare Professional on an anonymous basis. If
multiple Healthcare Professionals refuse consent, then the Transfer of Value data can be
aggregated and shall indicate the total number of Healthcare Professionals included in
the aggregation.
7.4. Platform for Disclosure
EGA member companies should disclose Transfers of Value in a way in which the public
can easily access such information. This means via the relevant company’s website, and/
or on a central platform (such as one provided by the relevant government, regulatory or
professional authority body, or an EGA national association).
Disclosures shall be made pursuant to the national rules and regulations, including the
EGA national association’s code, in the country where the EGA member company or
the affiliate holding the contractual relationship with the recipient is located, or where
the physical address of the recipient is located. If an EGA member company decides to
disclose Transfers of Value in the country where the recipient address is located but the
company has no residency or affiliate in that country, the EGA member company shall
disclose such Transfers of Value at European regional level.
It is the EGA member company’s responsibility to ensure that the information is acces-
sible online for a reasonable period of time.
7.5. Other Acceptable Forms of Disclosure
EGA member companies do not need to report under the EGA Code if they are subject
to, and currently report, Transfers of Value to Patient Organisations, Healthcare Professio-
nals and Healthcare Organisations under either (1) the transparency reporting regimes
of other self-regulatory associations (such as the EFPIA Transparency Code) or (2) local
transparency reporting laws and regulations, provided that these alternate reporting re-
gimes are at least as robust as the EGA’s, including public availability of reports.
7.6. Implementation Period
EGA member companies will have a 12 month implementation period starting from the
date of adoption of the disclosure paragraph, i.e. December 2015, which corresponds to
January 2017. All relevant Transfers of Value allocated in 2017 will have to be disclosed
during the following reporting period, starting from January 2018 and at the latest by 30
June 2018.
EGA national associations will have a 6 month period for implementation of the disclo-
sure requirements starting from the date of adoption by the EGA General Assembly.
7.7. Frequency of Disclosing
Disclosures shall be made on an annual basis and each reporting period shall cover a full
calendar year.The first reporting period shall be the calendar year 2017 and the first disclo-
sures shall be made from January 2018. Companies are encouraged to disclose as early as
possible, and at the latest within 6 months after the end of the relevant reporting period ■

EGA Code of Conduct

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EGA Code of Conduct