Transfer of Value


There is no public disclosure rule for value transfers made by pharmaceutical companies. However, according to the Regulation on the Promotional Activities of Pharmaceutical Products for Human Use (“Promotion Regulation”) dated 3 July 2015, the pharmaceutical companies shall notify TITCK about any value transfers that exceed 10% of the current monthly gross minimum wage, to health institutions, organizations, universities, health professionals, and members of professional associations, trade unions, associations and foundations, operating in the field of health, and non-governmental organizations established for the protection and development of health, in terms of sponsoring scientific meetings, making donations, or obtaining consultancy services. The notification for the mentioned value transfers that materialize in one calendar year shall be made in the format determined by TITCK, in detail, and within the first six months of the following year. The notifications must be made via electronic system launched by TITCK.

In order to fulfil this obligation, companies are required to obtain the consent of the healthcare professionals or healthcare organisations before any value transfer takes place. All consent forms had to be updated, together with the Code on the Protection of Personal Data, published in 2016.

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