EFPIA Disclosure Code

    1. The European Federation of Pharmaceutical Industries and Associations (efpia) issued a Disclosure Code in 2014 to bring transparency about the relationship between the pharmaceutical industry and Healthcare Professionals (HCPs) / Healthcare Organizations (HCOs).
    2. Spexis implemented a procedure to ensure to be able to collect transfers of value to HCPs and HCOs in accordance with the efpia disclosure code. Starting with transfers made in 2017, certain defined transfers of value provided by Spexis will be disclosed on an annual basis by the end of June of the subsequent year. The transfers of value relevant to Spexis’s interactions with HCPs and HCOs are in the following categories: Grants to a HCO, speaker and consultancy fees to HCPs, payments for travel, registration fees to attend a medical education congress and Research and Development (R&D) related transfers of value.
    3. The transfers of value will be reported by country, based on the recipients’ addresses. In accordance with applicable data privacy laws, Spexis may only publicly disclose personal data if recipients have given consent to such disclosure. In case a recipient has given such consent, the corresponding transfer of value will be reported on an individual basis, including personal data such as the recipient’s name and address. If no such consent has been given, the transfer of value will be reported on an aggregated basis. In accordance with the efpia disclosure code, R&D related transfers of value are reported on an aggregated basis only.