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.

However, within the scope of COVID-19 measures, firstly, on 19 March 2020, it was regulated that the activities of product promotion representatives, for the purposes of product promotion, by visits made to physicians, dentists and pharmacists in all health institutions / organizations, including pharmacies, were stopped, and it is regulated that activities may be carried out electronically. Later, this issue was readdressed and, gradually, physical visits were allowed, except for hospitals where patients with COVID-19 were being treated.

Again, within the scope of the measures dated 19 March 2020, it was prohibited to leave promotional materials during the visits by the product promotion representatives, but it was regulated on 16 November 2020 that for those physicians, dentists, and pharmacists who requested promotional materials, the same may be left in accordance with the hygiene rules.

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 payments to physicians and HCOs are regulated by the law. Amendments to various laws were made in 2014, establishing 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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