1. Transparency of payments to healthcare professionals: ABPI plans for a central platform for individual disclosures 2016 June 2014

2. The Code obligation

3. Individual disclosure 2016 General Obligation. Subject to the terms of this Code, each Member Company shall document and disclose Transfers of Value it makes, directly or indirectly, to or for the benefit of a Recipient, as described in more detail in Article 3 For Transfers of Value to an HCP: Contribution to costs related to Events. Contribution to costs related to Events, such as registration fees and travel and accommodation (to the extent governed by Article 9 of the HCP Code) Fees for Service and Consultancy. Transfers of Value resulting from or related to contracts between Member Companies and HCPs under which such HCPs provide any type of services to a Member Company (or any other type of funding not covered in the previous categories) Research and Development Transfers of Value. Research and Development Transfers of Value in each Reporting Period shall be disclosed by each Member Company on an aggregate basis

4. Format for disclosures Section 2.04: Platform of Disclosure. Disclosures can be made in either of the following ways, provided that they are unrestricted and publicly available: (i)on the relevant Member Company’s website in accordance with Section 2.05; or (ii) on a central platform, such as one provided by the relevant government, regulatory or professional authority or body or a Member Association, provided that disclosures made on a central platform developed at the initiative of Member Associations shall be made, so far as possible, using the structure set forth in Schedule 2.

5. Why? Makes data available in the most meaningful way Positions the UK as an exemplar across Europe Provides the opportunity to develop a template for best practices which can be exported to and replicated in other markets Enables opportunity to extend this beyond a pharma story Opportunity for co-creation with the healthcare professional community 5

6. Where are we now? EFPIA Disclosure Code BoM approval of central platform ESHLSG Consultation on disclosure Amend ABPI Code of Practice (what) BoM approval of technical approach Decision on hosting, funding and data model Stakeholder engagement Amend ABPI Code of Practice (how) System build, test & delivery

7. How the system will work 7 HCPs/HCOs will have a role in checking the financial data from companies prior to publication. Companies have other options regarding checking of data (such as when the contract/written agreement is signed). This entails adding unique identifiers to all HCPs/HCOs. This process will be managed by Cegedim (no additional workload for companies). This process is included as part of the costs. It ensures data is clean, complete and up to date but crucially ensures accurate search functionality. Companies to collect HCP/HCO financial data through their relevant financial systems, and collate into a standard template (modelled on the EFPIA template). Cegedim will maintain the database and ensure HCP/HCO information is relevant and kept up to date. The public website will have two components: 1)Search engine (searchable platform ) 2)Full disclosure data from companies (alphabetised) on a separate page

8. Data specification template 8 Schedule 2 - TEMPLATE Article 2 - Section 2.03 Full Name HCPs: City of Principal Practice HCOs: city where registered Country of Principal Practice Professional Address Unique country local identifyer OPTIONAL Donations and Grants to HCOs (Art. 3.01.1.a) Contribution to costs of Events (Art. 3.01.1.b & 3.01.2.a) Fee for service and consultancy (Art. 3.01.1.c & 3.01.2.c) Transfers of Value re Research & Development as defined (Art. 3.04) TOTAL OPTIONAL (Art. 1.01)(Art. 3)(Schedule 1)(Art. 3) Sponsorship agreements with HCOs / third parties appointed by HCOs to manage an Event Registration Fees Travel & Accomodation Fees Related expenses agreed in the fee for service or consultancy contract INDIVIDUAL HCPs INDIVIDUAL NAMED DISCLOSURE - one line per HCP (i.e. all transfers of value during a year for an individual HCP will be summed up: itemization should be available for the individual Recipient or public authorities' consulation only, as appropriate) Dr A N/A Dr B N/A etc. N/A OTHER, NOT INCLUDED ABOVE - where information cannot be disclosed on an individual basis for legal reasons Aggregate amount attributable to transfers of value to such Recipients - Art. 3.2N/A Aggregate N/A Number of Recipients (named list, where appropriate) - Art. 3.2 % of total transfers of value to individuals - Art. 3.2N/A %% HCOs INDIVIDUAL NAMED DISCLOSURE - one line per HCO (i.e. all transfers of value during a year for an individual HCO will be summed up: itemization should be available for the individual Recipient or public authorities' consulation only, as appropriate) HCO 1 N/A HCO 2 N/A etc. N/A OTHER, NOT INCLUDED ABOVE - where information cannot be disclosed on an individual basis for legal reasons Aggregate amount attributable to transfers of value to such Recipients - Art. 3.2AggregateAggregatedAggregate N/A Number of Recipients (named list, where appropriate) - Art. 3.2 % of total transfers of value to individuals - Art. 3.2%%%N/A AGGREGATE AGGREGATE DISCLOSURE N/A OPTIONAL

9. Consulting in partnership with HCPs Support for public disclosure of paymentsSingle searchable databaseInclusion of other sectorsProactive role for health professionalsImpact on collaboration

10. HCP consultation on individual disclosure …..with the principle that payments from commercial organisations to individual health care professionals should be transparent Figures are percentage of respondents

11. …..with the principle that payments from commercial organisations to individual health care professionals should be publically declared Figures are percentage of respondents HCP consultation on individual disclosure

12. …..with that a system of disclosure should take the form of a publically searchable, single database Figures are percentage of respondents HCP consultation on individual disclosure

13. …..that individual health care professionals should play a role in the disclosure of payments received from commercial organisations (e.g. submitting information or validating the information submitted by others), alongside the submission of the same information by industry? Figures are percentage of respondents HCP consultation on individual disclosure

14. Contact details Andrew Powrie-Smith APowrie-Smith@abpi.org.uk 07786 262345 Victoria Saunders VSaunders@abpi.org.uk 02077 471445

15. Transparency of payments to healthcare professionals Individual disclosures 2016 Magdalene Campbell and Andrew Powrie-Smith, ABPI 23 April 2014