Meals, Educational Items, and Gifts
When we interact with healthcare professionals (HCPs), patients, and other individuals, we may occasionally provide modest meals and educational items. We must exercise good judgment at all times and comply with all regulations that apply to our highly regulated business, including all disclosure laws and anti-kickback/bribery statutes. It’s important that we make sure our activities never interfere with HCPs’ decision-making or inappropriately influence their medical judgment.
How we do it
- We never give or accept gifts or business courtesies (such as entertainment) that could influence someone’s ability to make decisions fairly and objectively. When in doubt, talk to your manager and Compliance.
- We have policies in place that help ensure meals don’t exceed monetary value limits and have a defined, legitimate business purpose. We align with local guidance, which varies by country and state.
- We align with global pharmaceutical codes of conduct to provide items to HCPs and patients that are designed for educational purposes only and are of modest value.
- We don’t provide items or services that are for the personal benefit of the recipient, and we don’t provide or pay for entertainment or recreational activities.
- We never offer or accept cash or cash equivalents; gifts or business courtesies that violate the law, Insmed policy, or the recipient’s policy; or gifts or business courtesies that are in poor taste or could embarrass or reflect poorly on Insmed.
- We understand and uphold the strict rules that apply to HCPs who are considered government employees.
Did you know?
Disclosure of payments, gifts, meals, and other transfers of value provided to HCPs is required by the U.S. Open Payments Law, France’s Loi Bertrand, and similar laws, regulations, or guidelines. We are required to comply with Insmed policies and procedures in this area.
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