模块4：HCO和PO的赞助

Sponsorship of HCOs and POs What, Who, How to comply when sponsoring an HCO or PO? HOWto comply-key rules to follow WHATis a Sponsorship? Sponsorshipmust neverserve as aninducementto prescribe, purchase, supply, orrecommend specific medicines. A sponsorship is afinancial or non-financialcontributionthat a pharmaceutical company makes tosupport anactivity organised by a HealthcareOrganisation (HCO), a Patient Organisation (PO), or aProfessional Congress Organiser(PCO). Independence :The sponsormust not control or get involved in the content or runningof the sponsored activity—beyond providing the agreed support. In return, the company receives a legitimate businessbenefit: for example, publicity, booth space, advertisingin the event programme, the opportunity to run asatellite symposium, or having its name associated withthe activity. Multiple sponsors encouraged:Never require to be the sole sponsor. On thecontrary, funding from several sources is preferable and should be actively encouraged. Transparency:Clearly acknowledge the company's support from the outset; obtainwritten permission before using an HCO's or PO's logo. Sponsored activitiesinclude medical congresses, ordisease-awareness projects. Medical&scientific merit: Sponsored activities must deliver genuine (bona fide)medical education—improving HCP knowledge in a disease area or improving patientoutcomes. e4ethics check:For large third-party European congresses (>500 HCPs from ≥5EFPIA countries), confirm a positive e4ethics/CVS assessment before committing anysupport. WHOcan be Sponsored? Healthcare Organisations (HCO) and PatientOrganisations (PO) (section 13.03) Fair Market Value:The promotional benefit the company receives (e.g., visibility, boothspace) must be proportionate to the sponsorship amount. When a company sponsors through a ProfessionalCongress Organiser (PCO), the support is understood tobe directed at the HCO/PO at arm's length (Annex B). Sponsorshipmust notbe used to cover the HCO's or PO'sroutine operating costs.Companies should assess on a case-by-case basis whether part of the sponsorshipmay cover overheads directly related to the sponsored activity. Companies may also financially support individual HCPsand PO Representatives to attend events (Article 13.01). Disclosure:Transfers of value (ToV) to HCOs must be disclosed under "Sponsorshipagreements with HCOs / third parties appointed by HCOsto manage an Event”.IndirectToVs through PCOs follow Annex B guidance.Financial and non-financial support toPOs must be disclosed per Article 24. Sponsorship of HCOs and POsReal Life Scenarios Q2: A pharma company didn't ask to bethe sole sponsor—but no othercompany came forward. Is this a Codebreach? Q3: Can a pharma company sponsor thedistribution of treatment guidelinespublished by a learned society? Q1: Can a pharma company sponsor theWi-Fi at a congress and display itscompany name on the login page? A:Yes—distributing such guidelines is apermitted activity under the Code.However, because of the risk that it couldbe perceived as product promotion, thecompany should carefully evaluate theperception created by its name beingassociated with treatment guidelines. A:Not necessarily. The rule is that acompany must not require to be the solefunder. If, despite encouraging multiplesponsors, the company ends up being theonly one, that alone does not breach theCode. A:No. Company or product names mustnot appear on items available to allcongress attendees, such as the Wi-Fiaccess page. Sponsoring companiesshould instead be acknowledged incongress-related materials and on theevent premises. Q4: Can a pharma company sponsorPatient Organisation representatives toattend a scientific congress? Q5: What types of items should bereported under "SponsorshipAgreements" for disclosure purposes? Q6: How should a pharma companydisclose sponsorship when a third partyorganisedan event on behalf of severalHCOs? A:Examples are rental of exhibitionbooths, satellite symposia at a congress,sponsoring of speakers or faculty, itemsincluded in anorganiser’spackage (e.g.catering, room hire, audio-visualequipment), learning sessions provided byan HCO. The Methodological Note canprovide additional clarification. A:Yes, provided that PO Representativesare allowed to attend, do not get access tothe HCP exhibition area (or as per localrules), the congress organiser offers aregistration option for such delegates, andthere are sessions in the agenda aimed atPOs and their representatives. A:If it is not possible to allocate thetransfer of value to each HCO individually,it is reasonable to assume similar levels ofinvolvement. In that case, divide the totalamount equally among the HCOs andreport each as having received an equalshare. The Methodological Note canprovide further detail. Curious to know more aboutSponsorship of HCOs and POs? Tip:Always check the applicable law and code in the countrywhere the sponsored HCO/PO is registered as well as th