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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.

The exchange between the pharmaceutical industry and the actors in the health care system is essential for the research of new treatments and the further development of proven therapies. This is the only way to improve the quality of medical care for patients. The pharmaceutical industry is aware that relations with healthcare providers take place in a sensitive area.

This is why the European Federation of Pharmaceutical Industries and Associations (EFPIA) adopted its new EFPIA Disclosure Code on 24 June 2013. Based on this, scienceindustries, as the responsible association in Switzerland, drew up the Pharma Cooperation Code (PKK), which came 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 2023

The signatory companies to the PCC disclosed the following total cooperation payments for 2022:

- CHF 7.4 million to healthcare professionals
- CHF 121.5 million to healthcare organisations
- CHF 88.9 million for research & development
- Around CHF 217.9 million in total

Cooperation payments to healthcare professionals increased by a good CHF 1 million in 2022 compared to the previous year. It therefore appears that more cooperation was established between professionals and companies, after a sharp decline in the two years of the Corona pandemic. The pre-pandemic level (more than CHF 11 million) was clearly not reached. This is probably due not least to the trend that for a long time now a shift in the direct support of professionals to health care organisations can be observed. 

The cooperation grants to health care organisations increased accordingly by more than CHF 15 million to a good CHF 121 million. Payments for research & development increased relatively significantly last year by a good CHF 7 million. These figures fluctuate considerably from year to year at the individual companies, which is probably explained by the changing intensity of activities in the area of clinical research. This was confirmed again in 2022.

Here are 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:

The proportion of donations disclosed under individual naming of recipients has again increased. On average, the consent rate among professionals was 92.4% (median 99.7%). This development is in line with the industry's goal of continuously increasing transparency in this area of cooperation. Almost half of the disclosing companies now achieve fully individualised transparency. The consent rate mong professional organisations also increased again and now averages 97.2%. 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%:

- Almirall
- Astellas
- Daiichi-Sankyo
- Ferring
- Grünenthal

- Ipsen Pharma
- Kyowa Kirin
- Takeda
- Theramex


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. 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.


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