Module 6

03/10/2024

Annual Disclosures

• Companies must document and publicly disclose annually certain transfers of value made directly or indirectly • Clause 28 HCPs, other Relevant Decision Makers, Healthcare Organisations

• Clause 29 Patient Organisations

• Clause 30 Public including patients and journalists

• Disclosure is on a central platform

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Social Media Guidance

• PMCPA have issued a supplementary guidance to the Code on Social Media (2023)

• Developed with stakeholders including MHRA

• Pharma companies should have guidelines in place on usage

• Personal use of social media by employees has potential to overlap with professional responsibilities

• Visibility of postings, liking, sharing

• UK employee ‘liking’ a global post, likely to be subject to the Code

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