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Best practice: 2024 Access to Medicine Index

GSK voluntarily discloses information about transfers of value to healthcare professionals

GSK demonstrates best practice by being the only company to proactively and voluntarily disclose information related to transfers of value in countries in scope of the 2024 Index.

Date

19 November 2024

Company

GSK

Location

Algeria, Dominican Republic, Ecuador, El Salvador, Egypt, Guatemala, Honduras, Jamaica, Morocco, Thailand and Vietnam

Focus

Promoting high ethical standards for engaging with healthcare professionals (HCPs) in low- and middle-income countries (LMICs) by publicly disclosing information on transfers of value

Action

Demonstrating responsible business practice by voluntarily disclosing information on transfers of value to HCPs in LMICs, despite the absence of any legal obligation or regulatory requirement

Aim

To uphold high ethical standards engaging with HCPs in LMICs by publicly disclosing information on transfers of value, promoting transparency and fostering accountability

When companies publicly declare their transfers of value to HCPs, they demonstrate transparency, increasing accountability in their interactions with HCPs and building trust in healthcare systems. Transfers of value can be financial or non-financial and relate to fees for services (for instance, speaking at conferences or symposia), sponsorship agreements, travel expenses, grants and research funding, among other activities.

Public disclosure of transfers of value diminishes the likelihood that pharmaceutical companies improperly or unduly influence HCPs to prescribe certain medications and, in turn, affect whether patients obtain the medicines they need. This also helps lessen the risk of any additional costs for treatment (overspending on unnecessary or inappropriate prescriptions, for example) on an already strained healthcare budget, which is often the case in LMICs.

In Europe and the US, pharmaceutical companies are required to disclose such transfers of value. Under the respective legislations, the European Federation of Pharmaceutical Industries and Associations (EFPIA) Disclosure Code and the Sunshine Act, companies must publish annual disclosure reports that detail payments and transfers of value made to HCPs. In LMICs, where healthcare systems may not be as robust and disclosure is not always mandated, there is a greater risk that HCPs will be vulnerable to inappropriate transfers of value from companies through their sales agents or marketing representatives.

Best Practice 

GSK demonstrates best practice by being the only company to proactively and voluntarily disclose information related to transfers of value in countries in scope of the 2024 Index. Notably, it discloses voluntarily for LMICs where there is no legal mandate or requirement in place*. While other companies in scope disclose their transfers of value to HCPs, they do so only when mandated by local law or regulation. GSK goes beyond the minimum obligation of compliance, upholding a high ethical standard in its interactions with HCPs in LMICs. In this, the company shows a strong commitment to responsible business practices.

On its website, GSK discloses the transfers of value it makes to HCPs in countries where it operates, including 11 LMICs in scope that do not mandate such disclosures: Algeria, Dominican Republic, Ecuador, Egypt, El Salvador, Guatemala, Honduras, Jamaica, Morocco, Thailand and Vietnam. The company also details its cumulative payments and includes averages paid per HCP where such information is legally permitted.

Conclusion 

The Index encourages all companies to make proactive, voluntary disclosures of transfers of value to HCPs, and not just when required to do so. To promote transparency and accountability while demonstrating the highest level of commitment to responsible business practice, companies should disclose transfers of value to HCPs that relate to all countries in which they operate, regardless of legal obligations or regulatory mandates.

*Includes and is not limited to adherence to codes for e.g., the International Federation of Pharmaceutical Manufacturers and Associations (IFPMA) Code of Practice and European Federation of Pharmaceutical Industries and Associations (EFPIA).

Sara Keller

Research Programme Manager

skeller@accesstomedicinefoundation.org

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