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V. Sales,Promotional, and Other Business Meetings
Companies may conduct sales, promotional, and other business meetings with Health Care Professionals to discuss for example, Medical Technology features, sales terms, or contracts. Often, these meetings occur close to the Health Care Professional’s place of business. It is appropriate to pay for reasonable travel costs of attendees when necessary (e.g., for plant tours or demonstrations of non-portable equipment) and/or to provide occasional modest meals and refreshments in connection with such meetings. However, it is not appropriate to pay for meals, refreshments, travel, or lodging of guests of Health Care Professionals or any other person who does not have a bona fide
professional interest in the information being shared at the meeting. See Section VIII for additional principles related to the provision of meals associated with Health Care Professional business interactions.
Frequently Asked Questions
Why does the Code not allow Companies to extend business courtesies to guests/spouses in connection with sales, promotional, and other business meetings?
AdvaMed’s Code of Ethics is mindful of the desire to avoid even the appearance that business courtesies are being given as improper inducements to promote a Company’s Medical Technologies. On the other hand, Companies may, as a matter of common courtesy and civility, provide occasional modest meals or refreshments for Health Care Professionals in connection with these types of meetings that are conducive to the exchange of information. The Code precludes the extension of these courtesies to persons, such as guests/spouses, without a bona fide professional interest in the meeting.
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May a Company conduct a sales, promotional, or other business meeting at a resort location and pay for a Health Care Professional’s travel to the meeting?
Generally, this would not be appropriate. Companies should be deliberate in selecting the location and venue for such meetings. Like location and venue selection for training and education meetings (discussed in Section III), Companies should select a location and venue that is appropriate for, and conducive to, accomplishing the purpose of the meeting. Selection of a resort location would not likely meet these standards and may give rise to an appearance of impropriety. In addition, the location should be evaluated for consistency with the provisions in Section V, which state that it may be appropriate at sales, promotional, or other business meetings to provide occasional modest meals or refreshments and, with respect to providing travel, that the travel be “necessary.” Furthermore, the Code provides for limited special circumstances of “plant tours and demonstrations of non-portable equipment” as specific examples of when travel might be necessary.
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May a Company indirectly provide meals or refreshments when the provision of meals or refreshments does not conform to the Code, for example, by reimbursing a distributor who provides these meals while marketing the Company’s Medical Technologies?
No. Companies should always promote adherence to the Code by intermediaries when they are engaged in marketing the Company’s Medical Technologies. A Company should never knowingly encourage or condone an intermediary’s engaging in conduct that would be prohibited by the Code if a Company engaged in it directly.
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