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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.

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 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 2021

The signatory companies to the PCC disclosed the following total cooperation payments for 2020:

- CHF 6 million to healthcare professionals
- CHF 83.5 million to healthcare organizations
- CHF 93 million for research & development
- Around CHF 182.5 million in total

Cooperation payments to healthcare professionals declined noticeably in 2020, presumably to a large extent because of the corona pandemic. It can be assumed that the corona measures not only led to a strong drop in direct payments in support of continuing education, but also affected other cooperation programmes to a certain degree. Cooperation payments to healthcare organisations fell to around CHF 93 million. These too are likely to have been affected by the corona pandemic, albeit to a smaller degree. Support payments for continuing education to expert societies are also likely to have declined because fewer events could be staged in 2020 or events had to be switched to digital channels, which resulted in reduced support payments. Payments for research and development rose substantially in 2020. Previous years have shown that these payments are subject to severe fluctuations across the different companies due to the varying intensity of activities in the field of clinical research in particular. The increase in 2020 seems to be due to increased research activities in the context of corona therapies and vaccine development.

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 trend for the disclosure of individual recipients of such payments is positive once again. The average consent rate for healthcare professionals was 87.8% (median rate as high as 93%). The fact that half of the PCC signatory companies reported consent rates of 93% or higher deserves recognition. The consent rate for healthcare organisations improved further to 94.9%. The median rate was 100% once again, whereby at least half of the PCC signatory companies reported consent rates of 100%. 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, the same as in the previous year.

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

- Almirall
- Boehringer Ingelheim (Switzerland)
- Daiichi-Sankyo
- Ipsen (Future Health Pharma)
- Janssen-Cilag
- Kyowa Kirin

- Otsuka Pharmaceuticals (Switzerland)
- Sanofi-Aventis
- Servier (Switzerland)
- Sunovion (Medius AG)
- Theramex (Future Health Pharma)


It should be noted that the disclosure rate was steady at a high level or could be improved further for a large majority of companies, which is encouraging in view of the effort involved. The result was disappointing for a few companies only. The Code Secretariat encourages these companies to improve their consent rates in order to further strengthen the constant positive trend recorded from the outset for the transparency initiative.


Further information on the subject:

Documents to download (PDF):


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