Industry codes in Iceland and Sweden were updated in February. Specific information on both revisions is provided below.
On February 19th, 2018, Frumtök, the Icelandic Association of the Pharmaceutical Industry, published a revised version of the Appendix on its website. The Appendix is a document which contains specific rules applicable to Frumtök member companies related to various aspects including transparency disclosure.
There are two changes introduced in the revised Appendix that affect transparency reporting:
- Travel expenses lower than 20.000 ISK (about 161, 34 EUR) should be excluded from the disclosure. Previously the threshold was set to 15.000 ISK (about 121, 00 EUR).
- Meal-related expenses, lower than the monetary thresholds set by art 10 of the Appendix may be excluded from disclosure. If expenses exceed the set limit, the total cost is to be disclosed
Changes are effective immediately, and therefore applicable to 2017 transfer of values to be disclosed in 2018 (submission deadline: June 30th, 2018).
On February 15th, 2018, LIF, the Swedish Association of the Pharmaceutical Industry, published a revised version of the Ethical Code of Conduct (“Code”) on its website.
There are two changes introduced in the revised Code that affect transparency reporting:
Reporting template for disclosure:
- The label “E/T” “Not applicable” has been added to i) the registration fees and T&A section under the category “contribution to cost of events” for HCPs and ii) to the aggregate section of the Donations to HCOs and Sponsorship agreements with HCOs/third parties appointed by HCOs to manage an event
- The word “Swedish Data Protection Act” has been replaced by “General Data Protection Regulation” (“Dataskyddsförordningen”) in the aggregate section label for HCPs
- The layout colors of the template have changed
The Code expressly states now that “Companies are strongly recommended to report transfers of values on the last weekday in May”, therefore the reporting deadline for this year will be May 31st, 2018.
Please note that changes are effective February 12th, 2018, therefore applicable to 2017 transfer of values to be disclosed in 2018 (submission deadline: May 31st, 2018).
Polaris is making necessary revisions to the Spend, Tracking, Analytics and Reporting (STAR) solution.
Polaris’ experts continually monitor transparency changes around the world, keeping our solutions and clients up-to-date with all legislation and codes. To learn more about how Polaris can work with you, visit our website or contact us.