Transparency

We at Bayer are convinced that close cooperation with and continuous education of healthcare professionals is key to achieving better outcomes for the patients we strive to help.

We are committed to transparency regarding how healthcare professionals (HCPs) and healthcare organizations (HCOs) are compensated by us for the time and expertise they provide. When collaborating with medical experts, we comply with applicable laws and regulations such as the EFPIA Disclosure Code in Europe and various local legal reporting obligations and fully respect the independence and integrity of these professionals.

The EFPIA disclosure code has been locally transposed by the Association of Innovative Pharmaceutical Manufacturers in Hungary.

These codes are designed to ensure that even the impression of potential conflicts of interest are avoided. By making the cooperation between the industry and the medical community more transparent, the general public can gain a better understanding of the high importance and value of this cooperation.

In order to make the nature and the extent of the interaction between the pharmaceutical industry and healthcare professionals and organizations more transparent, Bayer will document and disclose all Transfers of Value in scope of the EFPIA Disclosure Code which it makes, directly or indirectly, to the benefit of a HCPs or HCOs. The reporting period is always a full calendar year.

The purpose of this methodology note is to allow any person accessing the report to understand how Bayer is documenting and disclosing the relevant information. It shall especially explain the details of the data collection and reporting methodology. The general rules of the EFPIA Disclosure Code apply to all member companies and all companies will disclose relevant Transfers of Value in a pre-defined format. However, some details of the reporting methodology are left for the individual companies to decide in order to allow the necessary flexibility to adjust to the internal processes.

If in doubt about the duty to disclose a specific Transfer of Value, our company will always aim for full disclosure. Only if a Transfer of Value is clearly out of scope of the Disclosure Code, it will not be included in the published report.

This methodology note is structured as follows: Based on a specific question, we will explain in detail, how Bayer handles disclosure of Transfers of Value to HCPs and HCOs. The general explanation will – where possible – also be illustrated by examples to ensure a clear understanding.

Methodology note

On 24 June 2013, the European Federation of Pharmaceutical Industry Associations (EFPIA) adopted the EFPIA HCP / HCO Disclosure Code, which deals with the publication of benefits for healthcare professionals and healthcare organizations in order to ensure transparency in the pharmaceutical sector. The Hungarian Transparency Code is the result of the sectoral self-regulation of innovative pharmaceutical member companies, which sets stricter requirements than the legal norms.

From 2015, all member companies, including Bayer Hungaria Kft., will record and publish the benefits they provide:

• In connection with medicinal products subject to medical prescription (‘RX’),

• directly or indirectly,

• for or for the benefit of a healthcare professional and healthcare organization.

Publication shall take place annually, within six (6) months of the end of the relevant reporting period, but no later than 30 June. The published information must remain public for at least three (3) years after the first publication, unless the beneficiary withdraws its consent to the publication in the meantime.

The disclosed data include transfers of value in four main categories.

In accordance with the provisions of the Transparency Code, following publication, by indicating the name of the healthcare professional / healthcare provider, the amount of the benefit will be published in aggregate according to each of the above categories - if the possibility of publication is provided.

The following are not subject to the obligation to publish:

• benefits related to non-prescription medicines only,

• transfer of equipment for medical and educational purposes,

• low value hospitality,

• free medical sample transfer,

• benefits as part of the normal process of purchasing and selling medicines.