Disclosure of payments made to HCPs in Malta
In recent years GSK has challenged the traditional commercial model of pharmaceutical companies with industry-leading improvements to how we do business. Our improvements aim to meet society’s growing expectation for organisations and individuals to act with transparency. This includes relationships between our industry and healthcare professionals (HCPs) or healthcare organisations (HCOs) so all of these interactions are conducted with integrity and transparency.
We fully support the European Federation of Pharmaceutical Industries and Associations (EFPIA) Code on the disclosure of individual transfers of value from pharmaceutical companies to healthcare professionals and healthcare organisations.
As of 1 January 2016, GSK ended payments to external HCPs to speak about our prescription medicines or vaccines including to audiences who can prescribe or influence prescribing. Since January 2016 GSK has also stopped providing financial support directly to individual HCPs to attend medical congresses, and instead now provides funding to independent bodies which select HCPs to attend such congresses. These changes go further than the current industry codes and therefore others in the industry. We continue to work with HCPs for non-promotional activities such as clinical research.
Under the code, and by 30 June 2016, EFPIA member companies across Europe, including GSK, have pledged to disclose transfers of value made in 2015 to HCPs and HCOs in connection with prescription medicines on an individual-named basis (aggregate by exception only).
The disclosure includes, for example, sponsorship for travel and registration fees to attend medical congresses, HCP consultancy fees for speaker arrangements or for chairing meetings, and grants to HCOs. Transfers of value to HCPs and HCOs for activities related to research and development will be disclosed as an aggregate number. The disclosures we are making in June 2016 under the EFPIA code relate to 2015 before GSK ended speaker payments.
We believe these disclosures will help create a better understanding of how the pharmaceutical industry works with HCPs and HCOs. Given the measures GSK has put in place we seek to increase confidence in, and understanding of, how and why we work with healthcare professions for the sustainable improvement of healthcare and in the best interests of patients. More information on our approach to the EFPIA code, how we are leading improvements to industry practices, and the importance of our partnerships with HCPs and HCOs can be found below, and is set out in greater detail.
Our disclosures for Malta
The links below will take you to our disclosures for Malta in line with the EFPIA code and the Pharmaceutical Research–Based Industry Malta Association (PRIMA) code, and to a note on the methodology used to set out the data in the report.
Our approach to implementing the EFPIA Code and HCP payments
By 1 January 2016, we ended in all parts of the world any payments to external HCPs to speak about our prescription medicines and vaccines although payments before this date are reflected in the 2015 disclosures. For work with external HCPs, which now entails non-promotional activities only, we have applied a “no disclosure consent, no contract” policy to enable and drive disclosure at an individual level and therefore fulfil our commitment to the EFPIA code. This means:
- Where individual-named disclosure is required under the EFPIA Disclosure Code we will actively seek the necessary consent from each HCP with whom we work.
- We will not work with HCPs where consent is not given. Where consent is given but subsequently withdrawn we will not then work with that HCP on activities covered by individual disclosure for a period of one year.
We will continue to work with HCPs for non-promotional activities including conducting clinical research and seeking advice on clinical relevance and appropriate communication of the results of our research, as well as identifying new research areas, as these interactions are an essential part of how we ensure medicines we develop meet patients’ needs.
We also continue to work towards publishing global figures at an aggregate level for payments to HCPs, for activities such as advisory services and clinical research. In many countries outside Europe we already publish payments to HCPs – for example, in Australia, Japan and the US. Find out more about our payments to HCPs in the USA, Europe and the rest of the world on the other pages within this section. We will continue to support and work towards increased transparency in other countries as industry associations and/or governments establish specific guidelines for disclosure.