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Jazz Pharmaceuticals (“the Company”) will disclose all Transfers of Value to healthcare professionals (“HCPs”) and healthcare organisations (“HCOs”) in accordance with the Code of Professional Conduct of Farmindustria, the Pharmaceutical Industry Association in Italy (“Code”). This document summarises the approach taken by the Company in calculating the figures stated.
For purposes of making its disclosures pursuant to the Code, the Company has defined healthcare organisations to include all hospitals, Clinical Commissioning Groups (CCGs), General Practitioner (GP) practices and other places of work for HCPs treating patients or providing associated advice or management services related to the treatment of patients. In addition, all medical societies (international, national or local) and all “networks” of associations for HCPs are included in the definition of healthcare organisations.
Private companies such as medical education agencies, or suppliers of “temp” nurses, etc are not included in the definition of healthcare organisations, especially where the majority of employees are non-HCPs. But see the notes under HCP below.
For the purposes of making its disclosures pursuant to the Code, the Company has included all employees of national health care services as HCPs regardless of their professional status. In addition, the Company regards all qualified healthcare professionals as within the scope of disclosure. A qualified healthcare professional is a person that holds the relevant license required to practice in Italy. The employment status of a healthcare professional does not affect the Company’s disclosure obligations, thus retired HCPs fall within scope.
Where HCPs are employed directly and exclusively by the Company their salary and benefits are outside the scope of the Company’s disclosure.
Note that HCPs have the right to opt out of individual disclosure (see below).
In accordance with applicable laws, rules, regulations and requirements relating to the privacy and security of Personal Data (as defined in the EU Data Protection Directive 95/46/EC or any replacement legislation), the Company shall obtain permission from the individual prior to disclosing personal data such as individual Transfers of Value. The Company has made every effort to secure the necessary permissions.
Where permission has not been obtained or where the individual HCP has refused permission, the Company has declared the total spend as an aggregate figure as a separate line entry within the relevant disclosure category.
All payments related to R&D are disclosed as aggregate figures in accordance with the Code.
Where payments were made in a currency other than Euros, the exchange rate will mean the exact equivalent in Euros according to the date on which the conversion calculation was made. All disclosures will be displayed in the local currency, category totals are displayed in Euros. The Euro totals will be calculated using the exchange rate on the day of payment (http://www.xe.com/). Variations will be greater if there have been significant movements in exchange rate during the reporting period.
The Company reports Transfers of Value as net (i.e. without value added tax or withholding tax unless the collection of net values is not possible through the Company financial systems).
There is an inevitable delay between the date on which a payment is approved within the Company and the date on which the payment may be made. The Company will disclose the details of the payment on the date the payment was made and not the date the activity was conducted.
Where projects run for several years, the Company will declare the payment amount relevant to the year in which each part of the payment was made. Thus a project which spans 2 calendar years and includes several individual Transfers of Value during that time will have two associated disclosures; one for each calendar year showing the value of the transfer made in that specific calendar year.
On occasion, a HCP who has provided a service to the Company may ask for their fee to be paid to charity. Typically the Company does not allow this and all payments are made directly to the HCP. In the exceptional circumstances of a payment to charity having been approved, the disclosure will be made against the individual HCP who has provided the service.
On occasion, a HCO will insist that any services provided by its HCP employees cannot be contracted with the individual HCP but must be a service contracted through the HCO.
In the event of the Company contracting for the services of a named HCP, the fee received by the HCP will be disclosed under that HCP’s entry. Any “administration fee” charged by the HCO will be disclosed as a fee for the service to that organisation.
If the HCP does not receive any additional payment for the service (e.g. because they are speaking at a meeting during normal working hours) then the full amount paid by the Company will be disclosed against the healthcare organisation as a fee for the service.
Where a HCP runs a private Company or partnership, charity, etc, for the purposes of their private income any payments to that organisation will be regarded for disclosure purposes as a payment to the HCP directly.
Similarly, organisations where the majority of employees or contracted suppliers are comprised of HCPs, the full value of payments made to such organisations associated with the services of a named or identifiable individual will be regarded as if it was a direct payment to the HCP.
The Company regularly contracts with advertising agencies and PR agencies, etc, for services related to its business. On occasion, the work commissioned by the Company might be contracted out to an individual HCP. The Company policy is that all such services must be disclosed to the Company by the contracted service agency. The Company will disclose any payments made to the individual HCP by the service agency as if the payment had been made directly by the Company to that HCP.
On occasion, independent companies may be approached by the Company to provide funding in relation to medical educational projects. The rules related to the Company’s funding in these circumstances require that the Company has no influence over the details of the project. The Company would not know whether or which HCPs had been involved in such projects. As such, the Company discloses Transfers of Value related to this type of project as payments to HCOs.
The Company will disclose all payments made to medical associations, HCOs, etc in relation to meetings. This includes direct funding such as sponsorship fees or the right to erect an exhibition stand, and indirect support such as providing a logistics agency or subsidising the cost of registration fees. The details are provided in the relevant line entry.
The cost of any sponsorship related directly to food is outside the scope of disclosure.
All costs associated with meetings run solely by the Company are outside the scope of disclosure except for fees paid to individual HCPs providing services as speakers, etc.
The Company supports the attendance of HCPs at meetings. The Company will disclose the associated Transfers of Value against the individual attendee. Where costs are not individually itemised (e.g. the cost of a bus transferring a group of HCPs from an airport to a conference venue), the total cost will be split equally between all those receiving the benefit.
Costs declared include transport, registration fees and accommodation. Costs related to subsistence are not declared but the meal costs are regulated by strict industry guidelines.
On occasion, the Company is asked by a HCO to provide financial support to assist its employees to attend medical meetings. Where the payment is associated with named individuals, the disclosure is made as if the money was transferred directly to the named HCP. Where the Company is not aware of the names of the HCPs receiving the support, the financial support is declared against the named HCO.
The Company is a global business that operates in many countries and therefore from time to time may contract HCPs and HCOs from different countries. For these arrangements disclosures will be made in the recipient’s country by the Jazz affiliate located or operating in that country according to local laws and regulations.
Payments made to local organisations by Jazz entities located in other countries are disclosed locally regardless of the source of funding.
All Transfers of Value to patient organisations are disclosed directly on the Company website Jazz Pharmaceuticals.
If the money is associated with an individual HCP working with the patient organisation, then the funding will be disclosed twice – the money for the HCP will be disclosed on the local disclosure platform against the individual HCP; and the overall project will be disclosed on the Company’s website against the patient organisation entry.
As an independently listed Company, the Company discloses all payments made directly from Company bank accounts and listed in the Company records as part of its normal business operations.
The Company does not disclose payments made by its shareholders or other stakeholders whether those be individuals or organisations.
Where the Company jointly markets a product with another pharmaceutical Company, the Company will only declare those payments made directly from the Company bank accounts and listed in the Company records as part of its normal business operations. Transfers of Value made by its co-marketing partners will be disclosed separately by those organisations.
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