Event venue

Legislation: Not applicable.

MA Code of Conduct

A venue should be selected for its appropriateness to enable the activity to be conducted and should not be chosen or utilised for the purpose of leisure, sporting or recreational activities.  Renowned or extravagant venues should be avoided.  

Venues should be conducive to education and not associated with sport, luxury and entertainment.  The meeting should not be able to be seen or heard by members of the general public.

Entertainment may not be provided to HCPs.

Not applicable.

No specific rules, provided necessary regulatory approvals are obtained.

No event may be held in venues renowned for their sporting or leisure activities. The venue must remain secondary to the scientific aims of the event.

Statutory Laws

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

INTERFARMA

The location must provide a suitable environment for the development of the proposed scientific and educational topics, with conference rooms and support material for presentations, workshops, professional meetings and, where appropriate, support material.

Inappropriate venues include (but are not limited to) cruise ships, theme parks, hotels or hotel complexes recognized for their predominant entertainment characteristics.

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.

Venues should be appropriate and conducive to the purpose of the business meeting or events organized. 

Avoid venues that are considered ‎lavish or extravagant in nature or ‎that are perceived as luxury venues. ‎Venues must have adequate ‎facilities and be conducive to the ‎scientific, educational, and business ‎purpose of the meeting. The venue ‎shall not be primarily known for its ‎entertainment, sports, leisure, or ‎vacation facilities (e.g., golf club, ski ‎resort, health spas, ‎beach/river/lake side locations or ‎casino).‎

No payment can be made for a ‎‎“clinic room rental fee,” “clean-up ‎fee” or any other similar type “fee” ‎that can reasonably be construed as ‎a direct or indirect payment to gain ‎access to an HCP. Paying for a ‎meeting room in a medical building ‎is acceptable if required for a ‎business discussion and provided ‎the “fee” is within fair market value ‎for a dedicated meeting room and is ‎not paid directly to an individual ‎HCP.‎

Activities can take place either in a hotel or an event center, or within the framework of a scientific congress.

Statutory Laws and Regulations

• No specific rules.

Codes of Conduct

Code of Ethics for Chinese Medical Doctors

• No specific rules.

RDPAC Code

• All medical interaction programs must be held in an appropriate venue that is conducive to the scientific or educational objectives and the purpose of the medical interaction program.
• Member companies should select venues to minimize travel and avoid public perception of extravagance; Theme-venues associated with leisure activities, such as spas, hot springs, holiday resorts, skiing, golf, gambling, cruise ships, etc. should be avoided. (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).
• A Third-Party organized procedure training must be held in a clinical setting or in an environment suitable for simulating medical procedures. The venue must not be selected because of its entertainment, leisure, or recreational facilities (Article IV).

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 transference 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: Companies must not carry out or sponsor their events in venues created specifically for recreation or tourism. Places predominantly linked with recreational, leisure or sport activities are forbidden as well.

ANDI's Chamber of Pharmaceutical Industry Code of Ethics and Transparency: There are not restrictions. Opening and closure events are permitted as long as they don’t include sports, leisure or entertainment elements or activities.

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: Pursuant to Article 19 (5) of the Ordinance, the event venue shall be "appropriate" and with predominantly business and / or convention services related offer.

The Code: According to Article 10 (3) of the Code, it shall be prohibited to organise or sponsor international events, unless:

• most of the invitees are from third countries, and given the country of origin of most of the invitees, it makes greater logistical sense to hold the event outside Croatia, or
• it makes greater logistical sense to hold the event outside Croatia, given the location of the relevant source or expertise that is the object or subject matter of the event.

Meetings must be held in appropriate event venues conducive to the main purpose of the meeting.

As a general point to note (which is relevant to all entries in this table for the Czech Republic), the provided hospitality must be:

(i) reasonable in level;

(ii) secondary (i.e., strictly limited and ancillary) to the main purpose or scientific objective of the meeting; and

(iii) not extended to persons other than HCPs.

Entertainment events (such as music, dancing or sporting) are not acceptable. Therefore, the pharmaceutical companies should avoid organizing meetings at venues which are renowned for their entertainment facilities.

In Denmark, there is no "negative" or "positive" list of "prohibited” and "permitted" meeting venues. Such a list could conflict with competition law rules.

In contrast, venues are required to be at a "reasonable level" (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).

No event may be held in luxury resorts or venues renowned for leisure facilities. In particular, castles or manor houses are prohibited venues (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".

IFPMA

All events must be held in an appropriate venue that is conducive to the scientific or educational objectives and the purpose of the event or meeting. Companies must avoid using renowned or extravagant venues.

See Event location.

No event may be held in venues renowned for their sporting or leisure activities. The venue must remain secondary to the scientific aims of the event.

The following is a non-exhaustive list of venues likely to be considered as sumptuary, or ostentatious, touristic, recreational, festive, etc.

• resorts;
• ships;
• castles;
• golf clubs;
• museums;
• amusement parks:
• aquatic centers;
• tourist attractions;
• abbeys;
• wine estates;
• famous monuments;
• concert halls;
• theaters;
• thermal structures;
• sites whose main activity relates to wellness or spa services.

StGB

No specific rules. However, the general principles outlined above apply.

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

The selection of the event venue should be exclusively based on objective criteria. The event venue should not have an incentive effect that decisively shapes its character. Particularly, event venues known for their leisure / entertainment value and/or that are considered extravagant should be avoided. For example, venues are likely to be considered extravagant if they do not primarily distinguish themselves as a typical business or conference hotel, but where the special luxurious or fancy facilities and / or the experiential character is clearly in the foreground.

No event may be held in venues renowned for their recreational and/or luxury characteristics.  The following is a non-exhaustive list of explicitly prohibited venues:

• Spas;
• Resorts;
• Castles;
• Religious sites. 

PBO: No specific rules.

HKAPI Code of Practice: Venue should be conducive to the scientific or educational objectives and the purpose of the event.

Lavish or extravagant venues should be avoided. The location and venue should not be the main attraction of the event/be perceived as such. (para 5.2 (b))

Code of Conduct: No specific rules.

The following is a non-exhaustive list of explicitly prohibited venues:

• Entertainment establishments (e.g. casino hotels);
• Extravagant venues offering leisure activities that are not compatible with the scientific nature of the event (e.g. SPAs, resorts);

venues specifically designed for hospitality services (e.g., “all inclusive” hotel arrangements).

Venues which are renowned for their entertainment or leisure facilities or are extravagant must not be used.  In particular, corporate hospitality involving sporting, entertainment or social events or activities may not be extended to HCPs.  Events which are organised or sponsored by or on behalf of a company must be held at an appropriate venue that is conducive to the main purpose of the event.

Events should be held in places such as hospitals, universities, scientific foundations, and conference rooms that guarantee scientific dignity.

The following is a non-exhaustive list of explicitly prohibited venues:

• resorts;
• ships;
• castles outside urban areas;
• farmhouses;
• golf clubs;
• museums;
• stadiums;
• aquariums;
• thermal structures;
• sites whose main activity relates to wellness or spa services.

Only hospitals, universities, scientific foundations, and congress halls allowed in case of local meetings.

FCC and its guidelines

Event venues 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 may be held at venues that are pretentious or renowned for their entertaining features.

A meeting or manifestation must be hosted at a suited venue, which:

• is subordinate in appearance and facilities to the main purpose of that meeting; and
• geographical location is objectively justified.

By way of example, a luxury resort of castle with ample amenities will likely not be permitted.

Medicines New Zealand Code of Practice

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

Events should be held at venues conducive to education and learning. E.g conference centre or training facility.

The choice of location and venue must be able to successfully withstand public and professional scrutiny and conform to professional and community standards of ethics and good taste.

The location and venue must not be chosen for its leisure, sporting or recreational facilities.

Norwegian Pharmaceutical law

No specific rules.

LMI Industry rules

All destinations and locations used by a Member Company to host an event, must be appropriate and relevant in relation to the purpose of the event, based on professional and logistic criteria. Venues that appear as appear "extravagant" or "luxurious" or typical holiday resorts/destination is not appropriate.

Please also see the prohibtion on third-party events and HCPs in public hospitals under Transport.

Polish Pharmaceutical Law

No specific rules.

INFARMA

Under the "Criteria for events assessment"

• the congress centers;
• the max. 4 stars hotels (with certain exceptions for 5 stars hotels);
• the restaurants (if giving lecture is possible there);
• the cultural venues offering professional conference services (if information about the conducted conference activities is generally available at their websites and no artistic, recreational, sporting, etc. events will be included in the program of the event / will not be available to participants as part of the event).

may be recognized as proper event venues.

PZPPF

Event venues must be appropriate and support the achievement of the main purpose of the event. Suitable venues may include clinical facilities, laboratory facilities, education facilities, conference centres, healthcare facilities, and business hotels.

Luxury hotels, holiday resorts, facilities known for their entertainment or recreational value, or extravagant facilities are never appropriate.

The places selected should be appropriate from a professional, operational, and economic standpoint in view of the purpose of the event.  The programme of the event (a) should be directly related to the professional activity of the participating healthcare professionals or to be relevant enough to justify their attendance (b) may include as lunches and dinners that take place during the event; and (c) cannot include entertainment activities (for example, leisure, recreation or sports).

No event may be held in venues renowned for their leisure, entertainment, sport, or luxury and extravagance facilities.  Particularly, the following venues are likely not to be permitted:

• spas;
• golf clubs;
• thermal structures.

The events should be held in Portugal, unless it is logistically more reasonable to hold the event in another country (a) taking into account the home countries of most of the participants; or (b) taking into account the location of the relevant resources or knowledge which are the object or topic of the event.

No specific rules

Theatre or museum halls (or similar culture related venues) may serve as event venues provided that no artistic event is held at the same time of the event or when access to exhibitions rooms is limited and if the use of such venues is justified by the required capacity for the event. 

Organizing events at 5 star hotels is prohibited.

No specific rules.

No restrictions identified.

Act on medical products

No specific rules. 

AIFP Code of Conduct

An event cannot be organized in places such as: holiday, golf or spa amusement, ski resorts, casinos, vineyards, five and more-star hotels, extra-urban facilities in refurbished castles and palaces, etc. 

ADL Code of Ethics

No specific rules. 

GENAS Code of Ethics

No member may organize or sponsor a professional event taking place outside the Slovak Republic, if: 

• the majority of the invited participants are not from abroad and have, given the origin of the majority of participants, greater logistical sense to organize an event in another country; or
• with regard to the location of relevant resources or expertise that is subject or purpose of the event, it makes more sense in terms of logistics to organize event in another country. 

All international professional events must be notified to the relevant subsidiary company or branch of a member in that State (if established in that State), or must request consultation at national level, except for events organized professional companies.

The Code

No event may be held at venues that are extravagant or renowned for their leisure or entertainment offers. Five-star hotels should be considered extravagant venues.

The following is a non-exhaustive list of explicitly prohibited venues:

• Sports resort hotels (e.g., with golf course, etc.),
• Theme park hotels,
• Winery hotels
• Five-star grand luxury hotels.

See above. Places known for their exclusivity shall be avoided. In general, a principle of moderation applies.

All events must be held in an appropriate venue that is conducive to the main purpose of the event. Hotels which are  known as recreational locations – such as resorts, spas, golf hotels – reputed for entertainment are not acceptable venues.

ABPI Code

Meetings must be held in appropriate venues conducive to the main purpose of the event. Lavish, extravagant or deluxe venues must not be used; companies must not sponsor or organise entertainment (such as sporting or leisure events) and companies should avoid using venues that are renowned for their entertainment facilities.

Consideration must be given to the programme, overall cost, facilities offered by the venue, nature of the audience, subsistence provided and similar. It should be the programme that attracts delegates and not the associated hospitality or venue.

Bribery Act

Similar factors as those referenced under the ABPI Code above will be relevant to an analysis as to whether an event venue constitutes an advantage given to induce, reward etc improper performance of a relevant function or activity. 

The Bribery Act does not place a bar on specific conduct, such as sponsoring or organizing sporting or leisure events, and guidance issued by the Ministry of Justice makes it clear that “for example, an invitation to foreign clients to attend a Six Nations match at Twickenham as part of a public relations exercise designed to cement good relations or enhance knowledge in the organisation’s field is extremely unlikely to engage section 1 as there is unlikely to be evidence of an intention to induce improper performance of a relevant function.” 

That said, HCPs will often be considered public officials, if they engage in work for public bodies or governmental organisations for example, and extra care should be taken given the heightened bribery risks that arise with engagement with such individuals.

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). See below. Other guidance may discuss 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).