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Disclosure obligation since 2016

Services - Pharma Cooperation Code

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.


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 as well as cooperations in connection with the assumption of logistics costs
  • 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 include a consent clause. If a person or organisation refuses to give consent, the names of payment recipients may not be disclosed.

Disclosure of cooperation payments in 2022

The signatory companies to the PCC disclosed the following total cooperation payments for 2021:

- CHF 6.4 million to healthcare professionals
- CHF 106.1 million to healthcare organisations
- CHF 81.6 million for research & development
- Around CHF 194.1 million in total

Cooperation payments to healthcare professionals in 2021 remained at a comparable level to the previous year. The effect of the Corona pandemic seems to continue in 2021. A shift in direct support to professionals towards healthcare organisations can be observed. The cooperation grants to healthcare organisations increased accordingly by more than CHF 10 million to a good CHF 106 million. Grants for research and development decreased slightly last year. As mentioned in the previous years, the donations of the individual companies fluctuate considerably from year to year, which can be explained by the changing intensity of activities, for example in the area of clinical research.  

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 three years here:

The proportion of donations disclosed under individual naming of recipients has again increased. On average, the consent rate for professioals was 90.4% (median 97.3%)*. This means that half of the PCC signatory companies have consent rates of 97.3% or higher. The consent rate for healthcare organisations also increased again to 96.0%. The median here again came in at 100%, meaning that at least half of the PCC signatory companies show consent rates of 100% for HCO. These averages were calculated on the basis of the individually disclosed number of recipients in relation to all recipients. If the consent rates are related to the disclosed sums, then they are somewhat lower on average, as in the previous year.

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

- ALK Abello
- Astellas
- CNX Therapeutics Ltd. & Sunovion (Medius)
- Fresenius
- Grünenthal

- Ipsen Pharma GmbH

- Mitsubishi Tanabe
- Organon
- Pierre Fabre
- Vifor Pharma


It should be noted that the vast majority of companies have maintained their individual disclosure rates at a high level or have been able to clearly improve them, which is gratifying in view of the effort involved. Few companies have achieved consent rates of less than 80% in relation to professionals. Among the companies listed above, three companies have implemented disclosure for the first time. Experience shows that sometimes lower consent rates can be achieved in the introductory year than in subsequent years. The above list should not obscure the fact that the consent rate in relation to the total cooperation amount could be clearly increased across all PCC signatory companies, because some large companies have made considerable progress here.


The Code Secretariat is reaching out on an individual basis to the listed companies to support them in raising their consent rates and thus further strengthen the positive development of the transparency initiative since its inception.


*For the sake of good order, it should be noted that one of the 68 PCC signatory companies was excluded from these averages. This company reported payments to professionals for the first time totalling CHF 3'300, which unfortunately were not disclosed individually. In relation to the CHF 6.4 million in cooperation grants to professionals, this sum is negligible, which is why this consent rate was not included in the calculation of the average values, because otherwise a distorted picture would emerge.


Further information on the subject:


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