Ethics and Compliance
Please see below Hospira’s self-certification scheme on Association of the British Pharmaceutical industry (ABPI) disclosures of payments and other benefits in kind made by Hospira to healthcare professionals, healthcare organisations and other relevant decision makers.
Healthcare professionals and healthcare organisations with whom Hospira works, provide the Pharmaceutical Industry with valuable, independent and expert knowledge, derived from their clinical and management experience. As owners of scientific knowledge and experts in medicinal products, pharmaceutical companies can be a unique resource to healthcare system and healthcare providers, which will ultimately benefit patients.
Throughout the medicines life cycle pharma companies work with scientists, healthcare professionals (HCPs) and healthcare organisations (HCOs). These collaborations are essential in addressing patient needs. Industry and healthcare professionals collaborate in a range of activities from clinical research to sharing best clinical practice and exchanging information on how new medicines fit into the patient pathway.
The European Federation of Pharmaceutical Industries and Associations (EFPIA) and its member associations, including ABPI in the UK, have adopted codes and guidelines to ensure that the interactions of their member companies with HCOs and HCPs meet the high standards of integrity and transparency. Building greater transparency to the relationships between pharma companies and healthcare professionals and healthcare organisations (HCOs) aims to building understanding of the collaboration and recognition of their value to patient care.
The drive to increase transparency of relationships with HCPs and HCOs is a Europe-wide initiative. EFPIA agreed the EFPIA Disclosure Code in June 2013. The EFPIA Disclosure Code includes requirements for public disclosure of certain payments to individual HCPs and HCOs from 2016 for payments made in 2015. A publicly available central database, together with the changes introduced in the 2015 ABPI Code, finalise the implementation of the EFPIA Disclosure Code in the UK.
Hospira UK hereby confirms that its disclosures report transfers of value made in 2015 conforming to the EFPIA Disclosure Code provisions in application of the following principles:
Hospira UK certifies that:
- Its disclosures include direct and indirect Transfers of Value (ToV), as defined in the codes and associated guidance issued by EFPIA
- Its Methodological Note describes the process it had followed in order to compile the data hereby disclosed
Methodology used for the collection and organisation of ToV is in line with the EFPIA Disclosure Code’s requirements and applicable codes
Hospira UK certifies that:
- Data collection complies with the requirements of the EFPIA Disclosure Code
- Action taken to seek consent from HCPs and HCOs (each as defined in the EFPIA Disclosure Code), where applicable
Aggregate disclosures are limited to Research and Development Transfers of Value and such Transfers of Value that cannot be disclosed on an individual basis for legal reasons.
Hospira UK certifies that aggregate disclosure is limited to the following topics:
- Research and Development Transfers of Value (as defined by EFPIA disclosure Code)
- Transfers of Value Recipients that have opposed to the publication on the grounds of protection of their private data
- If an HCP or HCO (where applicable) has provided consent to individual disclosure only in respect of part of the Transfers of Value he/she/it received, all Transfers of Value to such HCP or HCO (where applicable) are being disclosed in the aggregate.
Seeking the consent of Recipients
Hospira UK certifies that it has used its best effort in seeking consent from HCPs and HCOs, where applicable, for individual disclosure.
Hospira UK applied the following principle “no consent – no work” whenever legally allowed
Data quality and integrity
Hospira has policies and procedures governing how and under what circumstances payments or other exchanges of value may be made to HCPs and institutions including how these activities/payments are to be captured within Hospira financial systems.
The process to provide the disclosure report data extraction from several transactional systems and the implementation of manual data collection across Hospira. The electronic and manual data retrieval processes are complex and pivot on colleague adherence to current policies and third party vendors providing accurate data.
The transparency team within Hospira Medical Division is accountable for ensuring that data is appropriately extracted, loaded in the repository system and posted to central national platform www.disclosureuk.org.uk. However the responsibilities for ensuring transactions are accurate extend through the organisation. The responsibilities are shared and begin with each colleague who initiates an HCP/institution related transaction adhering to established process which outlines appropriate documentation and expense classification. Business Process Owners for each transaction types (e.g., speaker programs, consulting) must also execute their duties, which include ensuring processes are followed, reporting any known violations and correcting known errors or misclassifications as soon as possible. The processes and responsibilities for these front end requirements are outlines in various corporate and divisional SOPs throughout Hospira.