GSK and Sandoz raise the standard for reporting transfers of value

Collaboration between pharmaceutical companies and healthcare professionals (HCPs) is essential in driving medical innovation, improving healthcare delivery and ultimately benefitting patients. However, without transparency, these relationships risk creating conflicts of interest that could influence prescribing decisions and undermine public trust. 

Transfers of value (ToVs) – payments or benefits provided by companies to HCPs or healthcare organisations (HCOs) – should therefore be disclosed publicly to ensure these interactions remain ethical and accountable. Transparency provides insights into the impact of these interactions and how they may contribute to antimicrobial resistance (AMR) when medicines are prescribed inappropriately, while also demonstrating that collaborations are conducted responsibly and in patients’ best interests. 

GSK and Sandoz exemplify this approach by voluntarily making ToVs information clearly accessible across a wide range of countries, setting a best-practice example for transparency and accountability. 

Voluntarily advancing transparency 

Both companies disclose ToVs for all countries where they report such interactions, providing a single, clearly accessible source of information on their websites. For each country, the reports are organised by year and include direct links to the disclosure documents. GSK and Sandoz also go beyond mandatory obligations, making this information publicly available in multiple countries where no legal requirements or codes of practice apply. In addition, GSK shares data on interactions with individual HCPs where the law allows and otherwise provides aggregated information that combines data from multiple HCPs to protect individual privacy. 

Beyond website publication, both companies also submit their ToVs data to other stakeholders where applicable, such as national platforms like the US CMS Open Payments website or the ABPI disclosure portal in the UK. While these publicly available platforms increase visibility, the primary responsibility for transparent reporting remains with the companies themselves. 

In comparison, most other companies disclose ToVs only where legally mandated, under other codes of practice or in just one country beyond these requirements, often in fragmented formats that require external searches to locate.  

Demonstrating long-term, accessible ToVs reporting 

GSK has led voluntary disclosure efforts since 2017, initially reporting aggregate payments to HCPs and HCOs before expanding to include individual HCP data, where allowed by law. Its multi-year, country-level reporting demonstrates a sustainable approach that can be maintained and updated in future years. Sandoz has similarly committed to continuous, multi-year reporting, including in countries without mandatory disclosure requirements. 

By centralising data, maintaining long-term reporting and disclosing across multiple countries, both companies demonstrate that ToVs information can be publicly accessible and comprehensible. Their approach provides a replicable model for other pharmaceutical companies while remaining compliant with local legislation. 

Companies positioned to drive change, guided by government oversight 

Continued progress in ToVs transparency relies on proactive company action supported by regulatory frameworks. Following GSK and Sandoz’s practice, companies can improve self-regulation by sharing clear, easy-to-access data on interactions with individual HCPs where the law allows. Industry and HCPs can also collaborate to harmonise disclosure systems through publicly available centralised platforms, making data easier to compare internationally and supporting ethical collaboration and effective oversight. 

Additionally, companies can further safeguard patient care by decoupling incentives from sales volumes and keeping them separate from the promotion of antibacterial and antifungal medicines. These measures help reduce the risk of inappropriate prescribing and preserve the effectiveness of essential medicines. 

Besides company action, government oversight remains an important factor. Regulations such as the US Sunshine Act – a federal law requiring companies to disclose ToVs above a specified annual value (also see Responsible Business Practices on p.xx) – complement voluntary initiatives, creating a consistent and reliable framework for disclosure. When combined with company-led efforts, strong policies and active oversight, these measures can drive lasting progress – ensuring that openness in collaborations between companies and HCPs continues to protect both patients and public health.