6. Business Meetings and Discussions
6.1.1
Members recognize their responsibility in ensuring that the selection of venues is appropriate and conducive to the purpose of the business meeting or events they organize. Members may provide reasonable meals/refreshments to Stakeholders. The provision of meals/refreshments must be ancillary to the activity associated with it. For business meetings and events held outside of Canada, Members must respect the applicable laws, regulations and self-regulatory Codes of the country where the business meeting or event is being held.1
6.1.2
No stand-alone hospitality or entertainment is to be provided and the provision of tickets or vouchers, is not permitted, with the exception of hospitality related to a charity event as referred to in Section 12.3.2.2 of this Code.
6.1.3
Les employés des membres ne doivent pas participer, en compagnie d’intervenants, à des activités regroupant, sans y être limitées, le golf, le hockey, le théâtre et les spas, sauf si celles-ci font partie des exceptions prévues à l’article 12.3.2.2 ou sont tenues dans le cadre de congrès ou de symposiums directement reliés à ces événements et n’ayant pas été organisés par les compagnies membres.
6.1.4
Members should ensure that the time and efforts of attendees participating in business meetings and events are solely dedicated to scientific, educational and business objectives and activities.
6.2 Venues
6.2.1
Members must conduct business meetings and/or events in an appropriate setting conducive to learning or conducting a business discussion.
6.2.2
Locations – Members must select geographic locations for the meeting and/or event where the location is not the main attraction of the event and could not reasonably be perceived as such2.
6.2.3
Venues – Members must avoid venues that are considered lavish or extravagant in nature or that are perceived as luxury venues. Venues must have adequate facilities and be conducive to the scientific, educational and business purpose of the meeting. The venue shall not be primarily known for its entertainment, sports, leisure or vacation facilities (e.g. golf club, ski resort, health spas, beach/river/lake side locations or casino).3
6.2.4
As the interpretation of reasonable can clearly vary across the country depending on city or province, the onus is on Members to ensure that the venue is not extravagant nor reasonably perceived as such.
6.2.5
Face-to-face in person business meetings and/or events must not be held in personal residences.
6.2.6
Under no circumstances shall a Member pay a “clinic room rental fee”, “clean-up fee” or any other similar type “fee” that can reasonably be construed as a direct or indirect payment to gain access to a Health Care Professional. Paying for a meeting room in a medical building is acceptable if required for a business discussion and provided the “fee” is within fair market value for a dedicated meeting room and is not paid directly to an individual Health Care Professional4.
6.3 Provision of Meals and refreshments
6.3.1General Principle
6.3.1.1
The provision of reasonable meals and refreshments to Stakeholders is considered acceptable as long as the primary objective of the interaction is to facilitate business discussions.5
6.3.2Standards
6.3.2.1
The number of Stakeholders attending a business discussion, excluding promotional or learning programs that are covered in Sections 5, 9 and 10 of this Code, must be reasonable and justifiable if subjected to scrutiny by Stakeholders. Honorarium must not be provided to Stakeholders attending a business discussion.
6.3.2.1.1
Member employees may invite a maximum of five (5) Stakeholders, per informal interaction, per Member company. Although there may be more than one employee from a Member in attendance, the number of Stakeholders cannot be increased to result in larger groupings.6
6.3.2.1.2
Member employees other than sales representatives and their direct supervisors may invite more than five (5) Stakeholders, per interaction, per Member Company when the legitimate purpose of such business discussion is documented through an agenda or through any other acceptable form of documentation.
6.3.2.2
Attendance to a business discussion is limited to invited Stakeholders. Under no circumstances can meals and refreshments be extended to their spouses/companions or their administrative staff.7