Wirtschaftsverband Chemie Pharma Life Sciences

Disclosure obligation since 2016


Transparency is the key to the creation of confidence in relations with the general public and patients. That is why the European pharmaceutical industry discloses the pecuniary benefits provided between the pharmaceutical industry and stakeholders in the healthcare sector.

What is it about?

  • What commitment have the PCC signatory companies made?
  • Which benefits are disclosed?

  • There are few exceptions from the obligation to disclose pecuniary benefits

  • How is disclosure effected?


On 24 June 2013, the European Federation of Pharmaceutical Industries and Associations (EFPIA) adopted the new EFPIA Disclosure Code. On that basis, scienceindustries as the responsible member association of EFPIA in Switzerland drew up the Pharma Cooperation Code (PCC) which entered into force in January 2014. The partner associations Intergenerika, Interpharma and vips have also subscribed to the PCC.

What commitment have the PCC signatory companies made?
Since 2016, the signatory companies disclose each year on their websites accessible to the public the  pecuniary benefits which they granted in the previous year to professionals (primarily physicians and pharmacists) as well as healthcare organizations (in particular hospitals and research institutes).

Which benefits are disclosed?
The term pecuniary benefits as defined by the PCC means remuneration granted either directly or indirectly in connection with pharmaceuticals for human medicine available on prescription only. The disclosure includes payments made e.g. for consultancy and the provision of services, financial support for research and development in the healthcare sector and cost contributions for the attendance of professionals at events.

There are few exceptions from the obligation to disclose pecuniary benefits, e.g.:
• normal commercial compensation for professionals when pharmaceuticals are ordered and delivered
• delivery of pharmaceutical samples without payment to professionals within the limits of the official recommendations
• information and training materials of modest value
• payment for meals (including beverages)

How is disclosure effected?
To achieve a high degree of transparency, disclosure should take place individually, i.e. naming the recipients in person.
This requires the consent of the persons or organizations concerned to such disclosure. For this purpose, the cooperation agreements between the companies and these professional persons and organizations must be supplemented by suitable consent clauses. The companies are currently in contact with these stakeholders for that reason.

Disclosure of cooperation payments in 2019

The signatory companies to the PCC disclosed the following total cooperation payments for 2018:

  • CHF 12.4 million to healthcare professionals
  • CHF 96.7 million to healthcare organisations
  • CHF 72.3 million for research and development
  • About CHF 181.4 million in total

You can find the key figures pertaining to the disclosure of cooperation payments in Switzerland for the individual signatory companies to the PCC for the last two years here:

The trend for the disclosure of individual recipients of such payments is positive once again. The average consent rate for healthcare professionals was 82.8% (median rate 87.8%). The fact that half of the PCC signatory companies report average consent rates of 87.8% or higher deserves recognition. The consent rate for healthcare organisations improved on average to 93.4% (median rate 98.0%), which means that half of the PCC signatory companies report average consent rates of 98% or more. These averages were calculated as the ratio of the number of individually disclosed recipients to all recipients. If the consent rates are compared to the total amounts disclosed, the average is once again slightly lower this year. 

The following companies reported consent rates for healthcare professionals of less than 80%:

- Actelion Pharma Schweiz
- Allergopharma
- Almirall
- Boehringer Ingelheim (Schweiz)
- Bristol Myers Squibb
- Daiichi-Sankyo
- Eli Lilly (Suisse)
- Future Health Pharma (IPSEN)
- Helvepharm
- Janssen-Cilag
- Meda Pharma
- Merck (Schweiz)
- Norgine
- Otsuka Pharmaceuticals (Switzerland)
- Sandoz Pharmaceuticals
- Sanofi-Aventis
- Shire Switzerland
- Stallergenes

Since the introduction of the transparency initiative, the industry has improved the consent rates every year and will continue to focus on further improving this rate, and thus to constantly increase transparency about cooperation payments.

Further information on the subject:

Documents to download (PDF):


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