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Turkey
transparency obligations overview
PHARMACUETICAL
MEDICAL DEVICE
Pharmaceutical Companies
What is reported:Transfer of any values exceeding 10% of current gross monthly minimum wage, including transfers of value related to:
a) Donation. (for HCOs)
b) Contribution to covering event-related costs.
c) Sponsorship agreement. (for HCOs)
d) Honorarium or Consultancy Fee.
e) Any other transfers of value.
(Refer to art 23 of the Code for details.)
AIFD mentioned: “Practically, article 22 of the AIFD Code (which is a transposition of the similar article from EFPIA Code) is not operational. Pharma companies only submit their ToV to TITCK (as stipulated in the 2015 regulation and the guideline on disclosures). Article 23 of the AIFD Code is the reflection of the TITCK regulation and the related guideline.”
Medical Device Companies
What is reported:
MedTech members: refer to the summary provided under Europe – Medical Device Companies.
ARTED Members: According to the ARTED Code, member companies shall disclose an aggregate amount related to any of the categories set forth below:
- Supports Provided to Scientific Meetings Organized by Third Parties (including Support for HCP Participation at Third Party Organized Educational Events) and,
- Grants to Healthcare Organizations (including Scholarships, and/or Grants for Public Awareness Campaigns)
Important notes:
- This information is provided for your convenience and should not be construed as legal advice. The applicability of these requirements to your organization depends on individual circumstances. The information is not exhaustive.
- Kindly check with your legal department and do not depend solely on the information provided here. Moreover, the rules mentioned could be subject to interpretation of local authorities/courts in the applicable jurisdiction. Lastly, be mindful of the latest update mentioned above. These rules and regulations change frequently, so it is important to determine whether the information provided reflects the most recent changes and is still applicable.
- Reporting dates are related to the transparency obligation regarding transfers of value by pharmaceutical companies and/or medical device companies (excluding – in most cases – suppliers of in vitro diagnostics) to HCPs and HCOs. These often are based on laws or rules in codes of conduct of industry associations. In case it is based on codes of conduct, your company only needs to disclose the transfers of value on the mentioned due date if your company is a member of the association that follows that code.
- Including a jurisdiction in the Legislative Watch does not guarantee that jurisdiction is available for reporting via the MediSpend Transparency Reporting Solution.
- Reporting date normally means the date the transfers of value need to be published. The deadline for e.g. submission/sending the complete information to the authority could be before that date, for example to give HCPs and/or HCOs and/or the authority/association who publishes the information, the possibility to check the data the pharmaceutical companies/medical device companies are going to disclose.
- The information does not take into consideration (unless explicitly mentioned):
- Transparency related to clinical trials (unless it concerns transfers of value as mentioned above)
- Transparency related to patient organizations (unless the patient organization is considered an HCO)
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