Disclosure of values

According to APME Ethical code article 12 and appendix C and C1 APME members will disclose the transfers of value in the way that is set by EFPIA.

  • The disclosure of the data shall be made at APME member companies website in Estonian and if needed in English no later than 1-st of June after the end of the relevant reporting year (the same time is also set by the law for advertising reports). The first disclosure of the data shall be made on 1-st of June 2016 based on the year of 2015 data.
  • Donations and grants, contribution to event related costs such as registration fees, travel and accommodation costs, fees for service and consultancy paid either directly or indirectly to health care professionals and pharmacists or health care providers shall be disclosed on an individual basis and research and development transfers of value shall be disclosed on an aggregate basis.
  • Disclosed fees shall be kept available at the APME member companies’ website a minimum of 3 years after the time such information is first disclosed. APME member companies shall maintain the relevant records of the disclosures made for a minimum of 5 years after the end of the relevant reporting year according to the archiving rules established within the member companies.
  • Violations of the obligation to disclose payments made either directly or indirectly to health care professionals and pharmacists or health care providers shall be handled by the APME Ethics Committee according to the Article 18 procedures and sanctions of this code.
  • All payments made either directly or indirectly to health care professionals and pharmacists or health care providers shall be disclosed in net amount of euros. Payments agreed in multiannual contracts shall be disclosed in the actual payment amount of the reporting year.
  • APME Member Company shall publish a note summarising the methodologies used by it in preparing the disclosures and identifying Transfers of Value for each category. The note shall describe the recognition methodologies applied and should include the treatment of multi-year contracts, VAT and other tax aspects, currency aspects and other issues related to the timing and amount of Transfers of Value.