Event location

Legislation: Not applicable.

MA Code of Conduct

There are no specific restrictions on event locations.  However, an overarching principle of the MA Code of Conduct is that all events initiated or sponsored by companies must be reasonable and appropriate with respect to hospitality, travel and accommodation.  They must uphold the integrity and reputation of the pharmaceutical industry.

No event should take place abroad, unless:  

• The majority of participants come from abroad; or
• The necessary resources or specialized knowledge are available at the foreign location.

No event should be held in locations where leisure and/or social programs take place in a close timely correlation to the event (i.e. within 24 hours before or after the event). The location must only be selected based on objective criteria.

No specific rules, provided the healthcare organization holds a valid facility license from the NHRA to conduct such event.

Events may only be held abroad if the majority of participants are coming from different countries or if it can be substantiated that it makes more sense to hold the event abroad due to the presence of relevant knowledge or infrastructure.

Locations which are known for their entertainment or extravagancy must be avoided.

Statutory Laws

No specific rules. Any specifics must be assessed on the case-by-case basis.

INTERFARMA

Hosting events in locations whose eminently tourist or entertainment appeal might undermine the scientific and/or educational nature of the event are not allowed.

Events that are organized by adherent companies shall happen at the same country in which the organizing Company or Adherent is headquartered, unless the choice for a foreign country is justified by security and/or logistical reasons, as in the case of events that bring together participants from different countries, in the case of a satellite symposium at international congresses, and in case the relevant resource or experience that is the object or subject of the event is located outside the country of the professional’s practice.

SINDUSFARMA

No specific rules. Any specifics must be assessed on the case-by-case basis.

ACESSA

No specific rules. Any specifics must be assessed on the case-by-case basis.

Face-to-face in person events must not be held in personal residences. ‎

The geographic location for the ‎meeting and/or event cannot be ‎the main attraction of the event and ‎cannot reasonably be perceived as ‎such.‎

Note: Capital cities and other large metropolitan cities considered to be commercial hubs are likely to be reasonable and appropriate locations for meetings. The appropriateness and reasonableness of a location should be assessed differently for local events attended by local health care professionals as opposed to regional or national events. The program for an event may justify a particular location if there are valid reasons for that location such as the availability of relevant expertise or appropriate research/educational facilities.

Consultant meetings must be held ‎in Canada. The only exception is ‎those held in conjunction with ‎international conferences provided ‎that no travel or accommodation ‎expenses are to be paid. If the ‎consultant meeting occurs before or ‎after the international conference ‎ends, room accommodations may ‎be reimbursed in conjunction with ‎the consultant meeting.‎

Activities can only take place in Chile. Exceptionally, events can occur abroad if doing so is appropriate and justified from a logistical or security standpoint.

Statutory Laws and Regulations

• No specific rules.

Codes of Conduct

Code of Ethics for Chinese Medical Doctors

• No specific rules.

RDPAC Code

• No member company may organize or sponsor a medical interaction program for healthcare professionals (including supporting individuals to attend such a medical interaction program as described in Article 7.2) that takes place outside of their home country unless the principles and requirements set by the IFPMA Code of Practice 2019, as well as the IFPMA Note for Guidance on Sponsorship of Events and Meetings are satisfied. (Article 7).

AdvaMed China Code

• Companies should adopt objective criteria to select locations and venues. Local alternatives should be considered before sponsoring travel for HCPs. Further, Companies are encouraged to consider China-based alternatives before sponsoring international travel for HCPs (Article IX).

RTVSS: It has no specific restriction or limitation. Nonetheless, pharmaceuticals financing the planning or making of conferences, discussions, workshops, meetings, seminars, symposiums, congresses, events and other academic or medical training activities must report any value transfer that exceeds one (1) minimum monthly wage during a six-month period that are made to the same recipient.

The minimum monthly wage for 2023 is: COP1,160,000 or approximately USD245.

The six-month periods go from January to June, and July until December of each year.

AFIDRO'S Code of Ethics: Pharmaceutical companies may not organize or sponsor national scientific or professional events relevant to the health sector that take place outside of Colombia, unless the main subject of the event is located abroad.

The Pharmaceutical companies cannot organize their own national events outside the territory either. Unless the majority of participants or the main purpose of the event is located abroad.

ANDI's Chamber of Pharmaceutical Industry Code of Ethics and Transparency: Companies should avoid choosing eminently tourist locations for the event.

Pharmaceuticals should also prefer to hold events in Colombia. Nonetheless, companies may organize or sponsor events for health professionals abroad when:

• most of the participants or the relevant related resource or expertise with the main purpose of the event, if it is located abroad.
• when due to logistics, proximity, relationship or other circumstances, the proper location is set outside of the country.

However, if the logistics, proximity, circumstance or other, the chosen location happens to be of a tourist nature or abroad, companies must ensure that the event’s agenda is focused on scientific, technical or training purposes. At the same time, mechanisms to verify the attendance of participants must be in place.

ANDI's Chamber of Medical Devices and Health Supplies Code of Ethics: The location of educational events should be modest and appropriate for conducting such events. In the case of devices, it is generally recommended that training sessions be held in locations where people normally operate the medical devices.

All business meetings must be held in appropriate locations and venues where there is an atmosphere conducive to the exchange of scientific information. It is not allowed to hold meetings in luxury hotels, resorts or paradisiacal locations.

The Ordinance: no specific provisions.

In general, Czech law does not prohibit organized meetings at venues outside the Czech Republic. There must, however, be strong and valid reasons for holding meetings at such venues.

These are that the majority of the invitees are from outside the Czech Republic and therefore it makes more sense to hold the meeting outside the Czech Republic or given the geographical location of the relevant resource or expertise that is the subject of the meeting, it makes more sense to organize the meeting outside the Czech Republic.

Holding of professional events at five-star hotels, gourmet restaurants castles and manor houses, golfing, skiing and beach hotels (in season), boat trips, etc., would not comply with the Promotion Code (ENLI, Guidance on ”The Pharmaceutical Industry's Code of Practice on Promotion etc., of Medicinal Products aimed at Healthcare Professionals" (The Promotion Code), p. 70).

Directive

No specific rules

EFPIA

All Events must be held in "appropriate" locations and venues that are conducive to the main purpose of the event, avoiding those that are "renowned" for their entertainment facilities or are "extravagant".

No member company may organise or sponsor an event that takes place outside its home country unless:

• most of the invitees are from outside its home country and, given the countries of origin of most of the invitees, it makes greater logistical sense to hold the Event in another country; or
• given the location of the relevant resource or expertise that is the object or subject matter of the event, it makes greater logistical sense to hold the event in another country. 

IFPMA

No company may organize or sponsor an event for HCPs (including sponsoring individuals to attend such an event) that takes place outside the HCP's country of practice unless it is appropriate and justified to do so from the logistical or security point of view. International scientific congresses and symposia that derive participants from many countries are therefore justified and permitted.

The Finnish Medicines Act or Degree

Hospitality at purely professional or scientific events must always be moderate and remain secondary in relation to the main scientific purpose of the event.

Code of Ethics issued by Pharma Industry Finland

The event must be organised in a venue that is purposeful in view of the programme. No event may be organised in locations that are renowned for their entertainment offer or luxury. The event can be organised abroad if there is a valid scientific or training-related justification to do so.

Events should be held in France, unless it is justified to hold the event in another country:

• Given the countries of origin of most of the participants;
• Given the location of the relevant resources or knowledge that are the purpose of the event.

The geographical location of the event must be in or near a city that is known to have a scientific or business center. It should also be easily accessible and chosen to reduce travel time for potential participants.

The event will always be held in places that are appropriate and conducive to the main objective of the event.

No event may be held in locations of touristic interest.  Particularly, restrictions apply to the following locations:

• seaside locations during summer season;
• mountain locations during winter season.

StGB

The StGB does not provide specific rules with regard to restrictions on event locations since this has to be assessed on a case-by-case basis.

However, the following general principles shall be considered for any kind of hospitality offered by pharmaceutical companies engaging or interacting with HCPs:

• Hospitality shall be "socially adequate" ("sozialadäquat") and improper advantage must not be granted. In order to assess whether specific hospitality is socially adequate the overall context of the business relationship or cooperation shall be considered;
• Hospitality shall not intend to or improperly influence the HCPs;
• Hospitality to spouses is generally not permitted (only in exceptional cases);
• Cash or cash equivalents (e.g. dinner vouchers) are strictly prohibited;
• There shall not be a temporal link between the hospitality and a business decision of the HCPs or its employer;
• The offering (and granting) of hospitality shall be fully transparent and documented;
• The manner of the hospitality must not violate internal policies of the employer of the HCPs.

Special care needs to be taken when interacting with public officials. The term public official is interpreted in a very broad sense under German Criminal law and HCP employed by hospitals may be qualified as public officials (e.g. physicians at university hospitals).

The benchmark regarding hospitality offered or granted to HCPs who qualify as public officials is significantly stricter under German Criminal Law than for other HCPs. In case of hospitality for public officials, it is therefore recommended to obtain the prior approval of the respective employer.

HWG

No specific rules. However, the general rules and restrictions on providing financial inducements and other gifts to HCPs may apply.

UWG

No specific rules.

FSA Code of Conduct Healthcare Professionals

Invitations to events are generally only permitted if they are job-related and science-oriented. The selection of the event location should be exclusively based on objective criteria. The event location should not have an incentive effect that decisively shapes its character. Particularly, event locations known for their leisure / entertainment value and / or generally considered extravagant should be avoided.

No event may be held in locations of touristic interest.  Particularly, restrictions apply to the following locations:

Touristic locations during summer season (i.e. between 1 July and 31 August) and winter season (i.e. between 15 December and 15 January);

Touristic locations, (including skiing destinations, between 15 January and 15 March).

PBO: No rules.

HKAPI Code of Practice: Member companies should avoid using lavish or extravagant venues. The location and venue should not be the main attraction of the event or be perceived as such. (para 5.2 (b))

No member company may organize or sponsor an event for HCPs (including sponsoring individuals to attend such an event) that takes place outside of their home city unless it is appropriate and justified to do so from a logistics or security point of view. (para 5.1 (a))

Code of Conduct: No specific rules.

Events may only be organized or sponsored by pharmaceutical companies at any specific location, if

• the resources/experts required for the professional content of the event are exclusively available at the particular event venue; or
• the costs of organizing the event at a location closer to the workplaces of the participants would be disproportionately higher.

Pursuant to the relevant local industry code, pharmaceutical companies should avoid organizing or sponsoring events taking place outside of Hungary.

All events must be held in appropriate locations and venues that are conducive to the main purpose of the event.

Events may not be held at the same time of sporting, entertainment or other leisure events or activities.

A company may not organise or sponsor an event or a participant at an event that takes place outside Ireland unless there is a valid reason to do so.

Events should take place in Italy where the majority of HCPs are Italian.

No event may be held in locations of touristic interest.  Particularly, restrictions apply to the following locations:

• Seaside locations between 1 June and 30 September;
• Mountain locations between 1 December and 31 March or between 1 July and 31 August.

Exceptionally, seaside locations that are either (i) the capital city of an Italian region or province or (ii) headquarters of major universities and hospitals are allowed provided that the congress works and the hospitality provided occur in the urban area of the city.  Locations near the sea or otherwise suitable for bathing remain prohibited.

FCC and its guidelines

Event locations must be reasonable and appropriate in light of normal business practices and not extravagant under normal social conventions.

The event will always be held in places that are appropriate and conducive to the main objective of the event.

No event targeted to Mexican HCPs may be held or sponsored outside Mexico, unless:

• more than 80% of the HCPs invited is based outside Mexico and the location is logistically more convenient for most of the HCPs attending; and
• there are justified safety or cost-efficiency reasons.

A meeting or manifestation may only be organized outside The Netherlands if:

• the event has a truly international character; and
• a significant part of the attendees and speakers originate from other countries; and
• the event is either organized by an HCP association, scientific organization not related to the pharmaceutical industry; or
• the content of the event has been approved by a scientific association which is independent from the pharmaceutical industry.

If the above-mentioned requirements are not met, the details of the meeting / manifestation shall preliminarily be submitted to the Code Commission for approval.

Medicines New Zealand Code of Practice

The location of the venue should be in the home country of a majority of attendees.

The location, venue, hospitality and travel and accommodation arrangements for a company organised meeting held in an overseas country that has New Zealand resident HCPs in attendance should comply with the most stringent country’s Code of Practice (i.e this Code unless the overseas country’s code is stricter.)

Companies must critically examine the proposed location and venue. It should not be excessive.

Norwegian Pharmaceutical law

No specific rules.

LMI Industry rules

No events should be located at destinations which are associated with sporting or leisure activities (unless the HCP recide in that area), or which have a reputation for being extravagant.

Events should take place in Norway, unless:

• the majority of invitees are from countries other than Norway and the destination seems reasonable given the place of residence of the participants; or
• the location of the organiser or expertise makes it more sensible to hold the event outside Norway; or  
• the location of the participants makes it more sensible to host the meeting outside Norway.

Polish Pharmaceutical Law

No specific rules.

INFARMA

Locations that are considered extravagant or famous should be avoided.

Events should not be organized outside Poland, unless it is justified by important substantive or organizational reasons, in particular, when the majority of invited people come from outside the country where the event is organized.

PZPPF

Locations known primarily for tourist or recreational reasons are prohibited.

An event should take place in the location that is most logistically appropriate, taking into account where the participants are coming from and the resources necessary to organize it. These can be large transport nodes and cities with the appropriate infrastructure.

No specific rules

Locations that are renowned for their entertainment facilities or are extravagant should be avoided. 

Events cannot be organized in well-known ski resorts during winter season (December-February), and seaside resorts and Danube Delta resorts during summer season (June-August). 

Events may be organized outside Romania if (i) the majority of the invitees are from outside Romania; or (ii) given the location of the relevant resource or expertise that is the object or subject matter of the event, it makes greater logistical sense to hold the event in another country.

No specific rules.

No restrictions identified.

Act on medical products

No specific rules. 

AIFP Code of Conduct

All professional events organized or sponsored must be held in appropriate venue which satisfies the criteria pursuant to this code of conduct and  adequate to the main purpose of the event while hospitality may only be offered only if appropriate and otherwise compliant with the provisions of this code of conduct. 

An adequate location is the Slovak Republic in the case of an event organized by the local representation of the company in Slovakia (international and domestic). Location is not limited in case of the international events organized by international companies and  symposium of companies with significant international participation. 

ADL Code of Ethics

No specific rules.

GENAS Code of Ethics

All professional events organized or sponsored by a member must take place in a reasonable place that corresponds to the main purpose of the event, while hospitality may only be offered if such hospitality is reasonable and in other respects in accordance with the provisions of this Code. An extravagant place or a place famous for its reasons shall not be considered a suitable place.

The Code

Events should take place in Slovenia, unless:

• the majority of HCPs are from outside of Slovenia;

• the relevant resource or expertise, which is the object or subject matter of the event, is not in Slovenia.

As a general rule, all forms of hospitality offered should be reasonable in level and strictly limited to the main purpose of the event. As a general rule, the hospitality provided must not exceed what healthcare professional recipients would normally be prepared to pay for themselves. This applies also to the following questions.

The following seasonal restrictions apply to event locations:

• No seaside locations during July and August.
• No skiing locations in the mountains between December and March.

Events may not be organized or sponsored outside of Spain unless it makes more sense from a logistical standpoint considering that:

• The majority of invited participants are from a foreign country; or
• The resource or relevant expertise is located in a foreign country, and it is the object or subject matter of the event (prior authorization from the Ethics Monitoring Unit).

The selection of location and venue for the meeting shall be reasonable in relation to the purpose of the meeting. The following is a non-exhaustive list of locations that shall be avoided according to the Ethical Rules for the Pharmaceutical Industry:

• winter sport locations during ski season;
• locations hosting major international events (e.g., sport events) at the same time of the event.

Companies shall not organise or sponsor an event, or the participation of health care professionals in events that take place outside the UAE unless (i) most of the attendees of the event are from outside the UAE and/or (ii) given the location of the relevant resource or expertise it makes more sense to hold the event in another country.

ABPI Code

Meetings at venues outside the UK are not necessarily unacceptable. There have, however, to be valid and clear reasons for holding meetings at such venues. For example, this may include a situation in which most of the invitees are from outside the UK and, given their countries of origin, it makes greater logistical sense to hold the meeting outside the UK. Another example might include a situation in which, given the location of the relevant resource or expertise that is the object or subject of the meeting, it makes greater logistical sense to hold the meeting outside the UK. Consideration should be given to the use of technology to avoid travel outside the UK e.g., webinars, virtual meetings, etc.

Further to this, companies should remind their affiliates outside the UK that the ABPI Code still needs to be complied with if UK health professionals attend events/meetings which they organise, regardless of whether such events/meetings occur in the UK or abroad.

As a general point to note (which shall be relevant to all entries in this table for the UK), it is advised that HCPs "[r]efuse all but the most trivial gifts, favours or hospitality, if accepting them could be interpreted as an attempt to gain preferential treatment or would contravene your professional code of practice".

Bribery Act

The Bribery Act prohibits the offering, promising, giving, requesting, agreeing to receive or accepting of a financial or other advantage intending to induce or reward or otherwise in exchange for improper performance of a relevant function or activity.  It also prohibits the bribing of a foreign public official with the intention of influencing them in their capacity as a foreign public official and intending to obtain or retain business or an advantage in the conduct of business.

Event location could be considered an “other advantage” in the context of the Bribery Act if it is lavish.  The factors referenced above in connection with the ABPI Code with regard to location would be relevant factors in determining the appropriateness of the location from a bribery perspective.

Federal Law & Implementing Regulations, & Government-Issued Guidance: The laws and regulations do not specifically enumerate or define "appropriate" versus "inappropriate" venues, but enforcement action and settlement history show that selection is likely to impact the government’s perception of potential intent to induce or reward. In addition, the HHS-OIG Guidance states generally, with respect to entertainment, recreation, travel, meals, gifts, gratuities, and other business courtesies that the AKS should be considered and that "compliance with the PhRMA Code with respect to these arrangements should substantially reduce a manufacturer's risk." 68 Fed. Reg. 23,721, 23,738 (May 5, 2003). Other guidance may discuss the appropriateness or inappropriateness of venues for certain HCP interactions (e.g., OIG Special Fraud Alert on Speaker Programs provides that speaker programs held at venues that are not conducive to the exchange of educational information, such as golf courses, wineries, and sports stadiums, would be suspect). 

State Laws & Implementing Regulations:  Several state laws reflect an expectation of reasonable and appropriate event locations (for example, New Jersey in reference to venues and circumstances conducive to bona fide services; other states through incorporation of the PhRMA and/or AdvaMed Codes). 

Industry Codes of Conduct: The PhRMA Code and AdvaMed Code address restrictions regarding event venues.  For example, the PhRMA Code states that for consulting arrangements with HCPs the venue and circumstance of meetings with consultants must be conducive to the primary focus of the meeting, and resorts are specifically not appropriate venues.  The AdvaMed Code states that companies should not select a setting because of its entertainment or recreational facilities (e.g., resorts in geographic locations renowned primarily as seasonal vacation destinations).