Transport

Legislation: Not applicable.

MA Code of Conduct

Companies may sponsor travel for HCPs attending an educational event in: 1) economy class only for domestic air travel, and international air travel to New Zealand; and 2) in economy or business class for all other international air travel.

The most direct route should be booked, without the allowance of more time at the destination than is reasonably justified to enable the HCP to effectively participate in the event/s.

Legislation: Not applicable.

MA Code of Conduct

There are no specific restrictions on train transportation.  Intercity business travel by train is not common in Australia.

All travel should be reasonable and appropriate in the circumstances.

Legislation: Not applicable.

MA Code of Conduct

A company may provide travel to HCPs only in direct association with an educational event or to undertake a consulting service for the company.

Economy class air travel only. Exceptionally, business class air travel may be allowed where the following conditions are met:

• The HCPs participate in the scientific event as a consultant; and
• The outward and/or return flight is longer than six hours, excluding flyovers.

Flexible tickets (e.g., additional luggage, cancellation option, etc.) are only allowed if certain conditions are met.

Transfers from home to the airport and/or railway station cannot be offered or reimbursed to HCPs participating in the scientific event, unless participating as a consultant and insofar as reasonable, or if the transport to the airport/railway station is by train.

For use of a personal vehicle, a maximum rate of EUR0.43 (toll included) is allowed. For long distances (> 500 km) this is limited to the price of an airline ticket in Economy class, at least to the extent that this constitutes a reasonable and cheaper alternative.

Parking costs at the event or at the airport/railway station may not be reimbursed unless the HCP participates as a consultant and the costs remain reasonable.

Statutory Laws

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

INTERFARMA

It is prohibited to offer first class tickets to professionals to participate in symposia, congresses, seminars, or professional meetings of any nature, without distinction, and to events organized by the Company or Adherent, by medical associations, Patient Associations, academia or any other public or private entities.

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.

Statutory Laws

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

INTERFARMA

Expenses with transportation must be limited to the occasions inherent to the event itself and be directed exclusively to the invited professional and may be extended to the days immediately before and after the official schedule, if logistical and transport aspects justify such concession.

SINDUSFARMA

Members can sponsor or reimburse expenses with travel tickets of the health area professionals in national and international events, during the period of the event, which can be extended to the days immediately prior to or after the official agenda, for logistics, locomotion and transportation purposes that will justify granting this sponsorship.

ACESSA

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

Travel and hospitality must always be modest and reasonable. Modest travel is generally defined as “economy” class, with “business class” (not “first class”) exceptions permissible only for bona fide reasons, such as travel of more than five (5) hours or for other special or medical reasons.

Reasonable transportation, lodging, meals, and registration fees relating to a sponsored international event may be provided to a HCP. Reimbursement or payment of personal incidental expenses or any costs associated with accompanying family members are not eligible for reimbursement.

Travel and hospitality must always be modest and reasonable. Modest travel is generally defined as “economy” class, with “business class” (not “first class”) exceptions permissible only for bona fide reasons, such as travel of more than five (5) hours or for other special or medical reasons.

Flights of health professionals contracted by a company to provide services will be carried out in accordance with the internal policies of said company. For the remaining health professionals who do not provide services, flights will be in economy class.

Statutory Laws and Regulations

• No specific rules.

Codes of Conduct

Code of Ethics for Chinese Medical Doctors

• No specific rules.

RDPAC Code

• Member companies may pay for transportations that are appropriate for the meeting destination but should avoid extravagant transportation services. (Article 7).

AdvaMed China Code

• Companies may provide for reasonable flights and incidental expenses for HCP travel. Companies are encouraged to pay for flights directly where practical.  Reimbursement of travel-related expenses over RMB 500 should not be made in cash. (Article IX).

RTVSS: It has no specific restriction or limitation. Nonetheless, pharmaceuticals financing travel and transportation payments that exceed one (1) minimum monthly wage during a six-month period to the same recipient must be reported.

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: Hospitality sponsorship may only include guest’s travel costs, which must be moderated and reasonable, no distinction is made for air travel.

ANDI's Chamber of Pharmaceutical Industry Code of Ethics and Transparency: It sets the same standard as AFIDRO’S Code of Ethics.

ANDI's Chamber of Medical Devices and Health Supplies Code of Ethics: It does not establish a distinction for air travel. However, it is states that sponsorships to attend educational events organized by third parties, including payments for transport, may not be provided directly to HCPs.  

When business meetings are held to discuss products, negotiations, or terms of sale at locations other than the HCP, this displacement must correspond to a legitimate and justified need.

RTVSS: It has no specific restriction or limitation. Nonetheless, pharmaceuticals financing travel and transportation payments that exceed one (1) minimum monthly wage during a six-month period to the same recipient must be reported.

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: Hospitality sponsorship may only include guest’s travel costs, which must be moderated and reasonable, no distinction is made for train travel.

ANDI's Chamber of Pharmaceutical Industry Code of Ethics and Transparency: It sets the same standard as AFIDRO’S Code of Ethics.

ANDI's Chamber of Medical Devices and Health Supplies Code of Ethics: It does not establish a distinction for train travel. However, it does state that sponsorships to attend educational events organized by third parties, including payments for transport, may not be provided directly to HCPs. 

When business meetings are held to discuss products, negotiations, or terms of sale at locations other than the HCP, this displacement must correspond to a legitimate and justified need.

RTVSS: None.

AFIDRO'S Code of Ethics: None.

ANDI's Chamber of Pharmaceutical Industry Code of Ethics and Transparency: None.

ANDI's Chamber of Medical Devices and Health Supplies Code of Ethics: None

The Ordinance: no specific provisions, see general rules above.

The Code: as a main rule, travel expenses may be paid only for economy class air travel. Exceptionally, business class shall be also deemed acceptable, provided that the flight in one direction from the place of residence of the participant of the event to the venue exceeds 4 hours in continuity.

The Ordinance: no specific provisions, see general rules above.

The Code: no specific rules.

The Ordinance: no specific provisions, see general rules above.

The Code: no specific rules.

There are no specific restrictions on air travel, provided it is (i) reasonable in level; (ii) strictly limited and ancillary to the main purpose of the meeting; and (iii) not extended to persons other than HCPs.

Therefore, in most cases the business class travel is likely to be considered as unreasonable in level (and thus not permitted).

Furthermore, the most direct route should be booked, without the allowance of more time at the destination than is reasonably justified to enable the HCP to effectively participate in the event/s.

No specific rules.

No specific rules.

Economy Class air travel maximum for flights within Europe and Economy Plus (such as “Economy Flex” or “Economy Premium”) air class travel for oversea flights maximum. Business Class air travel may exceptionally be allowed by ENLI. Business class is acceptable in all instances where the traveler is wheelchair bound or otherwise disabled.

Air travel in First Class (where First Class is at a level above Business Class) is never permitted (ENLI, Guidance on "The Pharmaceutical Industry's Code of Practice on Promotion etc., of Medicinal Products aimed at Healthcare Professionals" (The Promotion Code), p. 75-76).

Directive

No specific rules.

EFPIA

No specific rules.

IFPMA

No specific rules.

No specific rules.

The Finnish Medicines Act or Degree 

No specific rules 

Code of Ethics issued by Pharma Industry Finland 

No specific rules 

See the general principles on hospitality in Accommodation.

The Finnish Medicines Act or Degree 

No specific rules 

Code of Ethics issued by Pharma Industry Finland 

No specific rules 

The substantial part of the expenses incurred for the events must be related to the scientific programme or training.

The event itself and the travels must be organised so that, excluding the travelling days, most of the time spent by the participants involves a scientific programme or training.

The hospitality must not extend any further than what the typical guest to the event would be prepared to pay for a corresponding event.

The transport must be of reasonable value and strictly limited to the purpose of the event.

It must be provided for in a written contract between the company and the HCP.

Such contract must be submitted to the relevant authority/professional association for prior (i) declaration or (ii) authorization, depending on the amounts at stake.

Please note that business class tickets and sumptuary expenses will likely be refused.

Key information (including the name of the company and the HCP, the date of the contract, the amount and type of benefit granted to the HCP) must be disclosed on the French public health transparency website.  

Economic class recommended

The HCP must provide invoices

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

Air travel is permitted if and to the extent appropriate and necessary for the arrival and departure at the venue (on the most direct route possible). Generally, only economy class air travel is permitted for intra-European flights. Business class air travel is permitted for intercontinental flights. First class air travel is generally not appropriate.

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

Train travel is permitted if and to the extent appropriate and necessary for the arrival and departure at the venue (on the most direct route possible). First class train tickets are generally considered appropriate.

The most direct route should be booked, without the allowance of more time at the destination than is reasonably justified to enable the HCP to effectively participate in the event/s.

Economy class air travel only.  Exceptionally, business class tickets may be offered in case of flights lasting for at least four hours.

PBO: No specific rules.

HKAPI Code of Practice: Standard economy class should be provided to professionals for one-way flight time of 5 hours or less, and standard economy class should also be the prioritised consideration for one-way flight time of more than 5 hours (and not include any travel or other sponsorship for their family members or companions) (para 5.2 (a))

Gratuitous payments in cash or cash equivalents (such as gift certificates, free flight upgrades) or personal services must not be offered to HCPs or any stakeholders under any circumstances.

The most direct route should be booked, without the allowance of more time at the destination than is reasonably justified to enable the HCP to effectively participate in the event/s.

Code of Conduct: No specific rules.

Restriction on train transportation (class; duration; etc.)

No specific rules.

any air, sea or overland passage given to or made available to him in his private capacity by a tradesman, firm, company, organisation or association by virtue of:

• the terms on which his spouse/parent/child is employed
• his membership of any organisation/association
• his spouse/parent/child being regular customer, or
• in the normal course of business (s. 4(1))

The above permission only applies if the advantage is equally available on equal terms to persons who are not prescribed officers, and if the donor of the advantage has no official dealings with the prescribed officer.

FCC and its guidelines

Air travel sponsored by pharmaceutical companies for HCPs as a means of unjustifiably inducing purchases of pharmaceutical drugs is prohibited.

However, reimbursing transport expenses incurred for business activities that pharmaceutical companies delegate to HCPs with objectively reasonable purposes are not restricted under the FCC.

FCC and its guidelines

Same as air travel.

The most direct route should be booked, without the allowance of more time at the destination than is reasonably justified to enable the HCP to effectively participate in the event/s.

In case of flights of less than six consecutive hours, only lowest class offered. In case of flights of six or more hours (excluding flyovers) where two classes are available, either class. However, in cases of flights of six or more consecutive hours where three or more classes are available, the best offered class may not be offered.

Flexible flight tickets may only be offered if there is adequate justification (e.g., luggage fees or because the activity may end sooner than expected) and must be accompanied by a statement that the flexibility will not be used to make changes to accommodate personal travel.

Additionally, compensation for travel may occur as following:

Car: 0.37€ /km;

Taxi: full in addition to public transport.

Compensation for travel time may only be for time during working hours.  Compensation for preparation may be paid, however both Travel Time and Preparation cannot both be paid.

Medicines New Zealand Code of Practice

The most direct route should be booked, without the allowance of more time at the destination than is reasonably justified to enable the HCP to effectively participate in the event/s.

Flights must be booked directly by the sponsoring company unless that would be impracticable.

Domestic travel must be economy class.

International travel may be business class where the flight exceeds 5 hours.  First class travel is prohibited.

There are no relevant restrictions relating to train travel in particular.

Intercity business travel by train is not common in New Zealand and impossible in most circumstances.

Medicines New Zealand Code of Practice

Travel may be provided to delegates of a company organised meeting only if the meeting content is related to the HCP’s area of expertise and the origin of the delegate justifies reimbursement. Land travel costs can be reimbursed where the expenses are verified.

Royal Australasian College of Physicians

Generally, attendees should meet the cost of travelling to pharmaceutical industry events.

If HCPs do accept financial support to meet the costs of travelling, they should be satisfied that this will not lead to a perceived loss of professional independence.

Norwegian Pharma Law

No specific rules.

LMI Industry rules

No specific rules except the general extravagant or luxurius test referred to under Event venue.

Norwegian Pharma Law

No specific rules.

LMI Industry rules

No specific rules except the general extravagant or luxurius test referred to under Event venue.

Regulation on HCPs availability to receive gifts of 29 August 2005 no. 941: General prohibition on HCP receiving benefits that are likely to influence health personnel's official actions in an inappropriate way.

Polish Pharmaceutical Law

No specific rules.

INFARMA

No specific rules.

PZPPF

Flights must be booked in economy class; business class flights may only be refunded in exceptional circumstances where justified.

Polish Pharmaceutical Law

No specific rules.

INFARMA

No specific rules.

PZPPF

Travel should always be on the most direct and logical route, taking into account the costs to the enterprise. Breaks in travel, side trips and travel extensions financed or facilitated by the company are prohibited.

As far as it is possible from a logistical point of view, arrivals and departures should coincide with the beginning and end of the meeting.

No specific rules.

The companies will be directly responsible for the payment of the necessary expenses (airplane tickets or train, etc.). No monetary reimbursement can be made to the HCPs for expenses incurred that come from suppliers that should have been paid directly by the pharmaceutical company, except in the case of minor travel expenses (cabs, mileage, etc.) with due justification of the same.

Travel provided for the HCP must be reasonable and should not cover a period of stay longer than the official duration of the event.

Class of travel should be in accordance with the management policy of the authority or facility where the healthcare professional practices.

If no management policy exists, class of travel depends on duration of the flight.

Medical product companies shall only pay reasonable and actual travel fees.

ABPI Code

Subject to the below, companies should only offer or provide economy air travel to delegates sponsored to attend meetings. Delegates may organise and pay at their own expense the genuine cost of an upgrade.

For flights that are scheduled to take longer than 6 hours, companies may pay for an upgrade from economy to premium economy or similar.

Bribery Act

Care should be taken to ensure that the nature of the travel is not such that it appears to constitute an inducement/reward to attendees for the improper performance of a relevant function or activity.  Operating in compliance with the requirements of the ABPI Code set out here will support in establishing that the travel is not nor is it intended to be such an inducement/reward.

ABPI Code

Travel costs must be strictly limited to the main purpose of the event/meeting; must be of secondary consideration and must be appropriate and not out of proportion to the occassion.

Travel costs should not exceed that level which the recipients would normally adopt when paying for themselves.

Bribery Act

As above.

Federal Law & Implementing Regulations, & Government-Issued Guidance: The laws and regulations do not specifically enumerate or define "appropriate" versus "inappropriate" air travel, 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 specifically notes that companies providing benefits, including travel, in association with information or marketing presentations could potentially implicate the AKS. 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. 

State Laws & Implementing Regulations: A number of states with laws of this type incorporate an expectation that travel expenses must be "reasonable" to be covered. 

Industry Codes of Conduct: The PhRMA Code indicates that, even in circumstances in which covering travel expenses is otherwise considered appropriate under the guidance, reimbursement should be limited to "reasonable" travel expenses. The AdvaMed Code also provides that travel costs for HCPs, where permitted, must be "modest and reasonable under the circumstances."

Federal Law & Implementing Regulations, & Government-Issued Guidance: The laws and regulations do not specifically enumerate or define "appropriate" versus "inappropriate" train transportation, 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 specifically notes that companies providing benefits, including travel, in association with information or marketing presentations could potentially implicate the AKS. 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. 

State Laws & Implementing Regulations: A number of states with laws of this type incorporate an expectation that travel expenses must be "reasonable" to be covered. 

Industry Codes of Conduct: The PhRMA Code indicates that, even in circumstances in which covering travel expenses is otherwise considered appropriate under the guidance, reimbursement should be limited to "reasonable" travel expenses.  The AdvaMed Code also provides that travel costs for HCPs, where permitted, must be "modest and reasonable under the circumstances."

Federal Law & Implementing Regulations, & Government-Issued Guidance: The laws and regulations do not specifically enumerate or define "appropriate" versus "inappropriate" travel considerations, 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 specifically notes that companies providing benefits, including travel, in association with information or marketing presentations could potentially implicate the AKS. 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. 

State Laws & Implementing Regulations: Some states detail restrictions on payments for travel for non-faculty HCPs.  For example, New Jersey prohibits any payment or direct subsidy to a non-faculty prescriber for the costs of travel associated with attending any education event or promotional activity. 

Industry Codes of Conduct: The PhRMA Code indicates that, even in circumstances in which covering travel expenses is otherwise considered appropriate under the guidance, reimbursement should be limited to "reasonable" travel expenses.  The AdvaMed Code also provides that travel costs for HCPs, where permitted, must be "modest and reasonable under the circumstances."