Public Disclosure of payments to Healthcare Professionals (HCPs) and Healthcare Organisations (HCOs)
We regularly work with HCPs and HCOs, for example inviting them to speak at medical educational meetings or seeking their advice and expertise on our medications and services to patients and the healthcare community. Individuals are compensated for providing these services to the industry at a fair market value and these payments are referred to as Transfers of Value (ToV). It can also include, for example, sponsoring an individual to attend an important medical congress by meeting their registration, reasonable travel and accommodation costs (also known as a benefit in kind). Organisations may be provided with funding to help with education for HCPs.
Janssen is requesting consent from all HCPs before declaring a ToV to the individual concerned. If consent is withdrawn then the individual details will not be published but disclosed in aggregate.
Detailed information on individual transfers of value can be accessed through www.janssentransferofvalue.com, a secure online portal, provided by Janssen. Consent to disclosure can be provided or withdrawn at any time through this website or you can contact the Janssen Disclosure team directly via email@example.com. As the disclosure of the payments will be done on an annual basis, consent or withdrawal of consent will apply to all transfers of value in a particular calendar year.
To enable us to comply with our regulatory requirements payments or other transfers of value (e.g benefits in kind), made by us to you for the current reporting year will be stored on our database and disclosed by the ABPI annually from summer 2016 onwards, as required by our industry Code of Practice.
For further information, speak to your local Janssen representative or contact the disclosure team on (+44)01494 567567 or email firstname.lastname@example.org
Addendum re disclosure of payments
The parties acknowledge that Janssen is required, by the Code of Practice for the Pharmaceutical Industry* (“the Code”), to document and publically disclose certain transfers of value made to healthcare professionals and healthcare organisations, and these include information about the payments or other transfers of value provided to the Recipient under this Agreement.
Accordingly, by signing this Agreement, the Recipient consents to the Company and/or its affiliates:
- storing and using such information relating to the Recipient and arising out of this Agreement for the purposes of its business (including, without limitation, the Recipient’s name and the amount and/or value of the transfer made to the Recipient under this Agreement);
- making public disclosures of such information consistent with the Code and with applicable laws, from time to time in force. Such disclosure may be made using any media, including printed reports, electronic communication, the website of the Company or its affiliates or other platforms, including the trade association website;
- disclosing such information to the trade association, its contractors and sub-contractors as may be required in furtherance of the objectives of the Code which include monitoring the activities of member companies and those agreeing to abide by the Code to ensure compliance with the terms and spirit of the Code, particularly in relation to the prohibition of inducements to supply or prescribe particular products;
- transferring such information to other affiliates and/or to any third party providing services to the Company, who may be established in jurisdictions outside the European Economic Area (the EEA), for the purpose of storage, use and public disclosure of such information and/or to comply with codes of practice and laws applicable in other jurisdictions to the Company and / or its affiliates concerning transfers of value made to health professionals and healthcare organisations. Such jurisdictions outside the EEA may not provide the same or adequate protection for such personal data.
The Recipient may contact the Company at any time to correct any mistakes or request deletion of personal information relating to the Recipient, but the consequence of a request for deletion that places the Company or its affiliates in breach of the Company’s obligations under applicable codes and laws is that the Company shall be entitled to terminate this Agreement on written notice to the Recipient.
- Association of the British Pharmaceutical Industry (ABPI) Code in the UK
- Irish Pharmaceutical Healthcare Association (IPHA) Code in Ireland
- European Federation of Pharmaceutical Industries and Associations (EFPIA) Code in Europe.
Date of prep: August 2018