Interactions with HCPs

Promotional activities of human medicinal products (“HCPs”), enteral nutrition products, and infant formulas for special medical purposes, are regulated under the Regulation on the Promotional Activities of Pharmaceutical Products for Human Use (“Promotion Regulation”) dated 3 July 2015.

Pursuant to the Promotion Regulation, any advertisement of products to the general public, whether directly or indirectly, through any public media or communication channels, including the Internet, is prohibited. The promotion of pharmaceutical products may be made only to physicians, dentists and pharmacists. Interaction between companies and patients shall, therefore, be at a minimum level.

Companies are required to apply to TITCK for patient support programs in order to implement a support and tracking program via third party companies authorized by TITCK in order to render Home Care Services.

Companies may enter into written agreements with HCPs to obtain consultation services. Conditions of such service agreements are not regulated by TITCK. The rules for such agreements are set by the industry via Ethical Codes.

On the other hand, rules regarding the payments to physicians and HCOs are regulated by the law. Amendments in various laws were made in 2014, setting the full-time employment principle for physicians working for a public health institution or university hospital. In this respect, in principle, all payments for services rendered by these physicians must be made to the revolving funds of their relevant institution. The rule does not apply for physicians who had a private clinic prior to the introduction of this principle in 2014, and there are other exceptions, as well.

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