Transparent collaboration with the healthcare community and patients is key to building trust and respect between the Pharmaceutical industry and the vast spectrum of health-related stakeholders.
Disclosure of value transfers
As a member of Medicines for Europe Lupin Atlantis Holdings SA (“Lupin”) is committed to adhering to and supporting the Medicines for Europe Code of Conduct (the “Code”). As a transnational pharmaceutical company developing and delivering a wide range of branded & generic formulations and biotechnology products globally Lupin engages independent experts or specialist organizations. Lupin views co-operations between the Pharma industry, Healthcare Professionals (“HCP”) and Healthcare Organizations (“HCO”) as instrumental in the research and development of innovative drugs that allow patients to live healthier, better and longer lives. Lupin deems it as only fair and appropriate to compensate such groups for their time and expertise.
What is the legal basis for the disclosure?
The Code requires member companies to disclose Transfers of Value (“ToV”) that could potentially pose a conflict of interest, or to encourage the recipients of the transfers of value to disclose them, where such disclosure would be in the best interest of patients or the public. The Code which applies to all European operations of inter alia all Medicines for Europe member companies aims at establishing a framework of standards and principles that promotes trust, responsible behavior, and respect, between pharmaceutical companies and the healthcare community, including HCPs, HCOs, patients and patient organizations
What is the definition of Healthcare Community, Healthcare Professional and Healthcare Organization in the context of Lupin’s Code disclosure report?
The term Healthcare Community includes Healthcare Professionals, Healthcare Organizations, Patients and Patient Organizations.
The term Healthcare Professional is defined as any natural person that is a doctor, a member of medical, dental, pharmacy or nursing professions or any other person who, in the course of his or her professional activities, may prescribe, purchase, supply, recommend or administer a medicinal product. For the avoidance of doubt, the definition of Healthcare Professional includes: (i) any official or employee of a government agency or other organization (whether in the public or private sector) that may prescribe, dispense, purchase or administer medicinal products and (ii) any employee of a pharmaceutical company whose primary occupation is that of a practicing Healthcare Professional, but excludes (x) all other employees of a pharmaceutical company and (y) a wholesaler or distributor of medicinal products.
The term Healthcare Organization is defined as any entity (i) that is a healthcare, medical or scientific association or organization (irrespective of the legal or organizational form) such as a hospital, clinic, foundation, university or other teaching institution or learned society or (ii) through which one or more Healthcare Professionals provide healthcare services. For the avoidance of doubt, wholesalers, distributors, and similar commercial intermediaries are not considered Healthcare Organizations.
Patient Organizations are not-for-profit organizations which are patient-focused, and in which patients represent a majority of members in their governing bodies.
What items payments will be disclosed?
A ToV can include anything of value that is provided (or “transferred”) by a Medicines for Europe member company (directly or indirectly via a third party acting at its direction) to a recipient, including monetary payments or in-kind benefits, such as meals, travel, hospitality, etc.
All values disclosed are based on value transfers actually made within the respective category. Such value transfers have been made to HCPs as booked in the relevant reported year. All values are disclosed for HCPs which have been engaged by Lupin.
Where is Lupin’s disclosure report published?
Lupin’s disclosure report has been published on the website https://lupin-neurosciences.com/healthcare-professionals/general/transparency-reporting/
Have HCPs/HCOs consented to Lupin disclosing ToV?
The consent of each HCP or HCO is required before individualized data can be released.
Lupin has sought to secure consent of all the HCOs and HCPs with whom we work but consent is voluntary and can be withdrawn at any time. Lupin believes it is important to make sure our relationships with HCPs are transparent and as such will continue working to encourage our partners to provide consent for full disclosure.
As Lupin has not been able to secure consent from all HCPs in the reported years, the respective ToV data is disclosed in aggregate for cases where consent is not available.
How does Lupin define the date of a ToV?
Lupin has included ToVs related to those activities that started as of, or after the 1st January of the reported year.
For further information about the Code please go to:
For inquiries and information about Lupin’s disclosure of transfers of value to HCPs and HCOs please contact Lupin at firstname.lastname@example.org.