The industry recognises that transparency is an important means of building and maintaining confidence. The operation of the Code, including the complaints procedure, is a demonstration of the industry’s commitment to transparency as are the requirement to declare pharmaceutical company involvement in activities and materials and the publication of detailed reports of cases considered under the Code. The industry’s global agreement to disclose certain clinical trial data is another example of the industry’s commitment to transparency. Companies also have to publish the summary details and results of non-interventional studies as well as the monetary value of certain support to patient organisations. ABPI
Other transparency changes, effective in 2012 and 2013, included disclosure of the total amount of fees paid to consultants for certain services and the total amounts paid to sponsor attendance at meetings organised by third parties. As set out in the 2014 Code, in 2015 and 2016 transparency will be extended in relation to fees and sponsorship provided to health professionals and healthcare organisations, including naming the recipients in many instances. 
Transfers of Value to Health Professionals and Healthcare Organisations 

Companies must document and publicly disclose certain transfers of value made directly or indirectly to health professionals and healthcare organisations located in Europe (as per Clause 21.1 of the ABPI COP 2014).
The transfers of value covered by Clause 21.1 are:

  • joint working in accordance with Clause 18.5
  • donations, grants and benefits in kind provided to institutions, organisations and associations in accordance with Clause 18.6
  • contracts between companies and institutions, organisations and associations in accordance with Clause 18.7
  • sponsorship of attendance by health professionals and appropriate administrative staff at meetings in accordance with Clause 19.5
  • fees paid to health professionals and appropriate administrative staff, or to their employers on their behalf, in accordance with Clauses 20.2 and 20.3
  • Contributions towards the costs of meetings paid to healthcare organisations or to third parties managing events on their behalf, which may include sponsorship of health professionals by way of registration fees and accommodation and travel.
This Clause 21.1 does not apply to transfers of value to patient organisations. These transfers of value are covered by Clauses 24.7 and 24.8 (as per Clause 21.3 of the ABPI COP 2014).
Disclosures must be made annually in respect of each calendar year. Disclosure must be in the first six months after the end of the calendar year in which the transfers of value were made. (as per Clause 21.4 of the ABPI COP 2014).

The information disclosed must remain in the public domain for at least three years from the time of disclosure (as per Clause 21.5 of the ABPI COP 2014).
Companies must document all disclosures and retain the records for at least five years after the end of the calendar year to which they relate (as per Clause 21.6 of the ABPI COP 2014).
Different categories of transfers of value can be aggregated on a category by category basis, provided that itemised disclosure would be made available upon request to the relevant recipient or the relevant authorities (as per Clause 21.7 of the ABPI COP 2014).
Where a transfer of value is made to a health professional indirectly via a healthcare organisation such a transfer should be disclosed once only, preferably as being a transfer to the health professional (as per Clause 21.8 of the ABPI COP 2014).
Where recipients of transfers of value cannot be identified for legal reasons, the amount attributable to such transfers must be disclosed on an aggregate basis. The number of recipients involved must be stated together with the percentage of all recipients that they represent and the aggregate amount attributable to transfers of value to such recipients (as per Clause 21.9 of the ABPI COP 2014).
Each company providing transfers of value must publish a note summarising the methodologies used by it in preparing the disclosures and identifying each category of transfer of value. The note, including a general summary and/or country specific considerations, must describe the recognition methodologies applied and should include the treatment of multi-year contracts, VAT and other tax aspects, currency aspects and other issues relating to the timing and amount of transfers of value for the purposes of this Code (as per Clause 21.10 of the ABPI COP 2014).