It is essential that research institutes, healthcare professionals, patient advocacy groups and other key players in health systems have access to up-to-date information on diseases and treatments. We help facilitate this access by sponsoring independent initiatives and medical capacity advancement programs. We also support outstanding research projects, for example through our Global Grants for Innovation. Transparency is our top priority in everything we do.
Our approach to interacting with health systems
We support health systems by providing information to professional medical associations, patient advocacy groups, university clinics, and other hospitals, following specific approval requirements and procedures and in accordance with applicable laws and codes. In countries that have statutory or industry obligations regarding the disclosure of transfers of value to health systems, we comply with these obligations.
How we ensure transparency and compliance at an organizational level
For all interactions with healthcare stakeholders, Group Compliance establishes internal policies and related review processes to ensure adherence to statutory requirements and transparency obligations. Group Compliance also provides the necessary training for all applicable employees and handles the respective communications. The Global Transparency Operations team serves as a center of excellence, providing support for transparency reporting and our end-to-end management process for interactions with healthcare professionals, healthcare organizations, patients, caregivers, and patient advocacy groups.
Our Group Internal Auditing function monitors the local implementation of these initiatives. Before entering into a collaboration with a third party that is not a healthcare stakeholder, we also apply a selection process based on a policy and standard operating procedure. This is part of our Business Partner Risk Management compliance program, which is conducted by Group Compliance. More details can be found under Compliance.
Our commitment: Group-wide guidelines and industry standards
Our Policy on Interactions with Patients, Patient Opinion Leaders and Patient Organizations provides a comprehensive framework for our interactions with these key stakeholders. Our guideline entitled Good Practice and Process Guidance: Engagement with Patients, Patient Opinion Leaders and Patient Organizations provides additional guidance for our interactions with these stakeholders. It reflects our longstanding commitment to prioritizing patient well-being. Through this policy, the supplementary guideline and specific local policies, we provide a robust guidance structure to support our employees in being compliant during their interactions with patients, patient opinion leaders and patient organizations.
In 2019, we updated our Items Provided to Healthcare Professionals policy, which guides our employees in providing these key stakeholders with items such as medical or educational materials. We want to help ensure that this is done for legitimate and lawful purposes in accordance with our Code of Conduct as well as with applicable policies, laws and codes.
Transparent reporting
In 2019, we continued to publish all financial and non-financial contributions that we made to European medical professionals and organizations in the health industry. As required by the EFPIA Disclosure Code, this information includes the names of individual recipients and their addresses as well as the purpose and amount of the transfer. Before publishing, we secured all necessary informed consent forms as required by the applicable data privacy regulations.
In addition to disclosing monetary transfers of value on an individual level, we continue to publish overall spending on our research and development activities as required.
We also adhere to all statutory transparency requirements worldwide, such as the Transparency Code of the German Association of Voluntary Self-Regulation for the Pharmaceutical Industry (FSA). Specific national laws and requirements are implemented by our local units. We consistently adhere to the applicable data privacy legislation and endeavor to ensure the full compliance of our partners.
Relevant employees participate in mandatory e-learning courses and classroom seminars to stay up-to-date on our policies and guidelines and important changes to transfer of value reporting requirements.
Collaborating with patient advocacy groups
Patient advocacy groups support patients, family members and caregivers, providing them with information on disease management. We also made it our goal to improve patient quality of life, which is why we support the vitally important work of these organizations. We ensure transparency on our voluntary unsolicited donations by publishing the details of contributions to European patient organizations on our website. The report is updated annually and includes all amounts, recipients and the purpose of each transfer of value, thus fulfilling our obligation as a member of EFPIA.
Transparently promoting medical research and education
We sponsor research and medical education around the world so that we can contribute to medical advances that will benefit patients. Through our Global Grants for Innovation, in 2019 we selected two new winners for Grants of Growth Innovation (GGI) and three new winners for the Grants of Multiple Sclerosis Innovation (GMSI). A total of 104 research proposals have been selected to receive research grants through the Global Grants for Innovation program since 2009.
Through our Global Medical Education and External Relations department, we organize non-promotional Medical Education Programs, either directly or by providing grants to Third Party Medical Education Providers to fund independent medical education programs. This enables the development and delivery of advanced medical training aimed at increasing the scientific knowledge and competence of scientists, physicians, nurses, pharmacists and other healthcare professionals in order to enhance medical practice and improve patient outcomes. As with our other partnerships, we take an entirely ethical, transparent and responsible approach aimed at providing fair, balanced and objective content that is designed to allow the expression of diverse theories and recognized opinions.
All direct and indirect financial support aligns with the principles of the EFPIA Code of Practice. According to our internal Medical Education Funding Policy and our Programs Policy, all requests for medical education funding are channeled through an approval process that falls under our R&D and Compliance functions. This process ensures that all funds available for medical education programs are granted according to established internal guidelines and criteria, while also complying with all applicable laws and industry codes.
In 2019, we continued our partnership with the International Pharmaceutical Alliance for Continuing Medical Education (iPACME). This group of 20 professionals from 17 different companies from around the world engages in continuous discussions on improving and harmonizing quality standards for continuing medical education. We also contributed to updating the EFPIA Code of Practice issued by the EFPIA Medical Education Working Group.
We continue to support research and education in and for low- and middle-income countries through a series of programs, with a focus on schistosomiasis and malaria.
Healthcare-specific Code of Conduct training
In 2019, we worked on a Code of Conduct-related training curriculum on dealing with dilemmas in healthcare-specific situations. We piloted the project in China, where 21 leaders participated in a very comprehensive training course. The aim was to improve their awareness and understanding of Code of Conduct-related dilemmas in healthcare-specific situations, for example when overhearing a conversation that may or may not constitute attempted bribery. This training will be rolled out in other countries in 2020.