Meals

Legislation: Not applicable. 

MA Code of Conduct

Any hospitality (food and beverages) provided by a prescription pharmaceutical company to a HCP must be moderate and reasonable as judged by local standards.

Legislation: Not applicable. 

MA Code of Conduct

In Australia – a maximum limit of AUD $120 per person (excluding GST and gratuities) per meal applies.

Prescription pharmaceutical companies should plan that any meal (food and beverages) provided in another country complies with the monetary limit set by the industry association in that country (where applicable) or, if there is no monetary limit in that country, the Australian principles apply.

Legislation: Not applicable.

MA Code of Conduct

Other than the monetary limit (AUD $120), there are no specific restrictions on where meals can be provided.

Legislation: Not applicable.

MA Code of Conduct

Prescription pharmaceutical companies may only provide hospitality (food and beverages) if it is secondary to the purpose of an activity.

Meals may only be offered in the context of events lasting longer than six hours.

Meals can only be offered during, or immediately before and/or after the events.   

The following limits apply:

• EUR 40 maximum per lunch, including drinks;
• EUR 80 maximum per dinner, including drinks;
• EUR 20 maximum per break.

Statutory Laws

No specific rules. Any specifics must be assessed on the case-by-case basis.

INTERFARMA

Expenses with meals are limited to the event itself and are related solely to the invited professional, and may be extended to the days immediately before and immediately after the official agenda, in case logistics and transport issues justify such extension.

SINDUSFARMA

Members can sponsor or reimburse expenses with food of the health area professionals in national and international events, during the period of the event, which can be extended to the days immediately prior to or after the official agenda, for logistics, locomotion and transportation purposes that will justify granting this sponsorship.

ABIMIP

The payment of meals to health professionals or health area-related professionals is allowed when conducted with the objective of discussing or exchanging scientific or educational information, and must be limited to modest values and a place compatible with the exchange of information. The Associate Company’s representative must be present throughout the time reserved to the meeting.

Occasional reasonable ‎meals / refreshments may be offered ‎to HCPs. ‎ 

The provision of ‎meals / refreshments must be ‎ancillary to the activity associated ‎with it.‎ 

Provision of reasonable meals and ‎refreshments without a business ‎discussion / meeting is unacceptable.‎ 

Under no circumstances can meals ‎and refreshments be extended to spouses / companions ‎or administrative staff.‎

The following are recommended limits:‎

• CAN 40 maximum for breakfast; ‎
• CAN 40 maximum for lunch (served in office);‎
• CAN 70 for lunch (served outside office);‎
• CAN 70 maximum for dinner (served in office);‎
• CAN 150 maximum for dinner (served outside office);‎

All the above limits include gratuity. CAN 115 maximum in case of evening receptions.‎

Statutory Laws and Regulations

No specific rules.

Codes of Conduct

Code of Ethics for Chinese Medical Doctors

No specific rules.

RDPAC Code

Meals should be moderate and reasonable, which should be interpreted as not more than RMB 300 per person per meal, with exceptions for rare occasions, which must be supported by appropriate approval and justification by the GM or GM-delegate(s) of the company (Article 7).

AdvaMed China Code

The meal should be incidental to the bona fide presentation of scientific, educational, or business information and provided in a manner conducive to the presentation of such information. The meal should not be part of an entertainment or recreational event. A Company may provide a meal only to HCPs who actually attend the meeting, but may not provide a meal where its representative is not present (Article VIII).

RDPAC Code

Member companies are allowed to cover appropriate meals and refreshments within Code limit, which is not more than RMB 300 per person per meal (Article 7).

AdvaMed China Code

Meals should be in a setting that is conducive to bona fide scientific, educational, or business discussions. Meals may occur at the HCP’s place of business (Article VIII).

AdvaMed China Code

Under no circumstances should companies provide alcohol or tobacco to HCPs (Article X).

RTVSS: It has no specific restriction or limitation. Nonetheless, pharmaceuticals financing meals or providing meal services that exceed three (3) minimum daily wages during a six-month period to the same recipient must be reported. 

AFIDRO'S Code of Ethics: Hospitality sponsorship may only include feeding costs of the guest, which must be moderated and reasonable, and only for the duration of the event. 

Snacks and food offered during the event must be moderate, reasonable and accessory to the main objective of the event. 

ANDI's Code of Ethics and Transparency: it sets the same standard as AFIDRO’S Code of Ethics.

RTVSS: The giving or payment for food and beverages that exceeds three (3) minimum daily wages during a six-month period to the same recipient must be reported.

The minimum daily wage for 2020 is: COP $29,260.1 or approximately USD $8.65.

If the meal, snack, or beverage exceeds 25,95 USD (three daily minimum wages) its payment or delivery must be reported.

A limit of 20% of the total event budget apply to closing dinners.

AFIDRO'S Code of Ethics: there is no value limit, just that meals value should be moderate, reasonable and accessory to the main objective of the event.

ANDI's Code of Ethics and Transparency: there is no value limit, it follows the same standard as AFIDRO’S Code of Ethics.

RTVSS: There is no limitation for the place that provides the meals, only their value. 

AFIDRO'S Code of Ethics: There is no place limitation standards, just that meals value should be moderate, reasonable and accessory to the main objective of the event. 

ANDI's Code of Ethics and Transparency: There are no limits on this subject, Code follows the same standard as AFIDRO’S Code of Ethics.

RTVSS: None. 

AFIDRO'S Code of Ethics: None. 

ANDI's Code of Ethics and Transparency: None.

The Ordinance: no specific provisions, see general rules above.

The Code: meals shall be limited to refreshments and/or meals during the event, according to Article 11.2 (1) lit.c of the Code.

The Ordinance: no specific provisions, see general rules above.

The Code: the maximum amount of costs of meals per person or per meal shall be HRK 500,00 (ca. EUR 66,00). In case of international events, the maximum value of meals set in the host country shall prevail.

The Ordinance: no specific provisions, see general rules above.

The Code: no specific rules, see general rules above.

The Ordinance: no specific provisions, see general rules above.

The Code: no specific rules, see general rules above.

All forms of hospitality offered to HCP’s must be proportionate in scope, proportionate to the professional content of the event, proportionate to the event and must be limited to the main purpose of the event.

AIFP

All forms of hospitality offered to HCP's must be proportionate in scope, proportionate to the professional content of the event, proportionate to the event and must be limited to the main purpose of the event.

Pharmaceutical companies must not provide or offer any meal (food and beverages) to HCPs, HCOs' members or POs' Representatives, unless, in each case, the value of such meal does not exceed the monetary threshold set by the code of conduct. 

Similarly to accommodation, the value of hospitality may not exceed the amount that these persons would normally be willing to pay themselves.

Not applicable.

But the standards set above must be kept in mind.

Not applicable.

But the standards set above must be kept in mind.

The following limits apply:

• DKK 400 maximum per lunch, including drinks, VAT and gratuities;
• DKK 700 maximum per dinner, including drinks, VAT and gratuities.

The maximum amount per day is DKK 1,200 (ENLI, Guidance on ”The Pharmaceutical Industry's Code of Practice on Promotion etc., of Medicinal Products aimed at Healthcare Professionals" (The Promotion Code), p 64). 

Directive

No specific rules.

EFPIA

No specific rules.

IFPMA

Refreshments and/or meals incidental to the main purpose of the event can only be provided:

• exclusively to participants of the event; and
• if they are moderate and reasonable as judged by local standards.

Directive

No specific rules.

EFPIA

Member Companies must not provide or offer any meal (food and beverages) to HCPs, HCOs’ members or POs’ Representatives, unless, in each case, the value of such meal does not exceed the monetary threshold set by the relevant Member Association in its National Code.

IFPMA

No specific rules.

The Finnish Medicines Act or Degree 

No specific rules 

Code of Ethics issued by Pharma Industry Finland 

No specific rules 

See the general principles on hospitality in Accommodation.

The Finnish Medicines Act  or Degree 

No specific rules 

See the general principles on hospitality in Accommodation. 

Code of Ethics issued by Pharma Industry Finland 

The following limits apply:

• EUR 45 maximum per lunch per person, including VAT;
• EUR 100 maximum per dinner per person, including VAT.

The Finnish Medicines Act or Degree 

No specific rules 

Code of Ethics issued by Pharma Industry Finland 

No specific rules 

See the general principles on hospitality in Accommodation. 

The Finnish Medicines Act or Degree 

No specific rules 

Code of Ethics issued by Pharma Industry Finland 

No specific rules 

See the general principles on hospitality in Accommodation. 

• Spontaneous meals (i.e. not planned in advance) related to the HCP’s profession are allowed within the limit of €30, twice per calendar year
• Meals offered during events can be allowed, subject to compliance with the rules detailed below

The meals must be of reasonable value and strictly limited to the purpose of the event.

It must be provided for in a written contract between the company and the HCP.

Such contract must be submitted to the relevant authority/professional association for prior (i) declaration or (ii) authorization, depending on the amounts at stake (threshold: €50 per meal, €15 per snack).

Key information (including the name of the company and the HCP, the date of the contract, the amount and type of benefit granted to the HCP) must be disclosed on the French public health transparency website.

Please note that starred-restaurant and sumptuary expenses will likely be refused.

StGB

No specific rules. However, the general principles outlined above apply.

HWG

No specific rules. However, the general rules and restrictions on providing financial inducements and other gifts to HCPs may apply.

UWG

No specific rules.

FSA Code of Conduct Healthcare Professionals

Meals may be provided if and to the extent appropriate and necessary in light of the specific job-related and science-oriented event. Generally, appropriate lunch may be provided for a full day event (including catering during breaks), but no additional dinner. The type of meals, refreshment and beverages provided should clearly take a back seat and not constitute an independent incentive to visit the event. Luxurious and / or extravagant refreshments and meals are not appropriate.

StGB

No specific rules. However, the general principles outlined above apply.

HWG

No specific rules. However, the general rules and restrictions on providing financial inducements and other gifts to HCPs may apply.

UWG

No specific rules.

FSA Code of Conduct Healthcare Professionals

Generally, there is a maximum of € 60.00 per meal. Maximum of 3 meals per day (but not € 60.00 per meal if more than one is provided on a given day, rather considerably lower for two meals and max. € 60.00 for one meal). The costs and time of meals should be appropriate as regards to the actual duration of the meeting. Extravagances are not appropriate. The maximum amount of € 60.00 might be judged more generously under the specific circumstances of the individual case.

StGB

No specific rules. However, the general principles outlined above apply.

HWG

No specific rules. However, the general rules and restrictions on providing financial inducements and other gifts to HCPs may apply.

UWG

No specific rules.

FSA Code of Conduct Healthcare Professionals

Since the specific job-related and science-oriented purpose of the event should be in the foreground, generally, meals should be provided at the event venue selected according to objective criteria mentioned above. By contrast, especial locations with experiential character (e.g. Michelin-starred restaurants) will likely give the impression that the focus is on the experiential character instead of the opportunity for professional discussion.

No specific rules

EUR 70 maximum per day, including VAT.

No specific rules

The Prevention of Bribery Ordinance

No specific rules. 

HKAPI Code of Practice

• Limited to refreshments and/or meals incidental to the main purpose of the event (para 5.3(f)).
• Should only be provided to participants of the event, not their guests; and if moderate and reasonable as judged by local standards(para 5.3(f)). 

Code of Conduct

No specific rules.

The Prevention of Bribery Ordinance

No specific rules. 

HKAPI Code of Practice

• HK$400 per attendee for breakfast/ lunch; maximum of HK$800 per attendee for dinner (excluding service charges/gratuity or incremental costs attributable to venue rental where necessary and identifiable) (Appendix, para 2).
• For meals provided in events overseas, the value should be reasonable by local standards in the relevant country and to the extent possible at a level comparable to the amount allowable in Hong Kong/ Macau (Appendix, para 2). 

Code of Conduct

No specific rules.

FCC and its guidelines

It is prohibited for pharmaceutical companies to provide meals to HCPs as a means of unjustifiably inducing transactions of pharmaceutical drugs.

Further, meals provided by pharmaceutical companies to HCPs must be reasonable and appropriate in light of normal business practices and not extravagant under normal social conventions.

FCC and its guidelines

The monetary limit for all kinds of meals is JPY 5,000 per person (excluding consumption tax).

FCC and its guidelines

The places where meals are provided must be reasonable and appropriate in light of normal business practices and not extravagant under normal social conventions.

The following limits apply:

• EUR 45 maximum per lunch;
• EUR 90 maximum per dinner.

The meals and refreshments that are offered must be subordinate to the main purpose of the meeting or manifestation. 

For instance, breaks from the substantive programme must be logical intermissions. By way of example, refreshments after an evening programme where a meal was also offered already is not permitted.

For either meetings or manifestation the meals may not exceed €75 per occasion.  

• Any cost for meals must either be included in the €500 per event / €1500 per year cap or the HCP may bear 50% of the cost; or
• For manifestations it must be included in the €75 per event / €375 per year cap.

Medicines New Zealand Code of Practice

• Any hospitality provided must be appropriate, clearly secondary to the medical education or business purpose of the meeting, and not excessive.
• Meals intended to be eaten outside the meeting ('dine and dash') are prohibited.

Royal Australian College of Physicians Guidelines

• In general, the Guidelines advise against accepting gifts and hospitality (including meals).
• In general, Hospitality should be provided by employers or attendees themselves.
• Hospitals, universities, academic institutions and medical centres should not accept pharmaceutical company-funded meals.

Medicines New Zealand Code of Practice

• Hospitality must not be excessive.

In general, HCPs should be satisfied that this will not lead to a perceived loss of professional independence.

Medicines New Zealand Code of Practice

• Hospitality must be appropriate, clearly secondary to the educational content and duration of the meeting and must not be excessive.
• Offering takeaway meals, or meals intended to be eaten outside the meeting, is prohibited.

In general, HCPs should be satisfied that this will not lead to a perceived loss of professional independence.

There are no applicable restrictions on the provision of alcohol.

However, HCPs should be satisfied that this will not lead to a perceived loss of professional independence.

Hospitality Rate A = Lunch: NOK 250.

Hosptality Rate B = Dinner: NOK 950. 

Hospitality rate A can be applied for promotional visits.

Events/work meetings must include at least 45 minutes of professional content in order for hospitality rate A to be applicable. 

Events/work meetings must include at least 90 minutes of professional content in order for hospitality rate B to be applicable. 

Events/work meetings that include at least 5 hours of professional content can use hospitality rates A and B in combination. 

At events/work meetings that include at least 5 hours of professional content, and for which participants need to arrive the evening before due to the timing of the meeting, a meal may be served the evening before the meeting for up to 50% of hospitality rate B.

Norwegian Pharmaceutical law

No specific regulation.

LMI Industry rules

Maximum value for meals (2020):

Lunch:  NOK 250.

Dinner: NOK 950.

Norwegian Pharma Law

No specific rules.

LMI Industry rules

No specific rules except the general extravagant or luxurius test referred to under Event venue.

A Michelin-starred restaurant would typically not be appropriate.

Norwegian Pharma Law

No specific rules.

LMI Industry rules

Serving of beer or wine with food is allowed in moderate amounts. Moderate is normally understood as 1-2 glasses. It is not permitted to serve alcoholic aperitifs or spirits.

Polish Pharmaceutical Law

No specific rules.

INFARMA

• PLN 200 for meals offered in Poland; or
• the amount determined by the relevant local organization in the case of meals offered outside Poland; or
• the equivalent of EUR 100 in the case of no maximum amounts established locally

- inclusive of taxes

PZPPF

No specific rules.

No specific rules.

No specific rules.

The following limits apply:

• RON 150 maximum for one main meal (lunch or dinner);
• RON 35 for coffee break.

Act on medical products

No specific rules. 

AIFP Code of Conduct

Hospitality offered in the form of meals should be limited to the amount of EUR 75 per the main course (lunch/dinner), EUR 100 for an all-day meal in the Slovak Republic and the amount of EUR 100 for the main course abroad. 

ADL Code of Ethics

No specific rules. 

GENAS Code of Ethics

No specific rules.

The Code

EUR 60 maximum per meal, including beverages, per person (including VAT) if the event is set in Slovenia. If the event is set abroad the monetary threshold set in the country where the event takes place shall prevail.

Refreshments should not exceed the usual meeting standards  (e.g. alcoholic beverages or excessive/expensive snacks).

In addition, for events of short duration, the level of hospitality shall be reasonable. In any case, it must be ensured that there are no elements that could damage the image of the pharmaceutical industry.

No meal may be offered at the following venues:

• Sports resort hotels (e.g. with golf course, etc.);
• Theme park hotels;
• Winery hotels;
• Five-star grand luxury hotels.

The following limits apply:

• SEK 300 maximum for lunch;
• SEK 850 maximum for dinner.

The cost of a meal (including drinks) provided by way of subsistence must not exceed £75 per person, excluding VAT and gratuities. 

The maximum of £75 plus VAT and gratuities is appropriate only in very limited circumstances, such as dinner at a residential meeting for senior consultants or a dinner at a learned society conference with substantial educational content. The cost of a meal (including drinks) should normally be well below this figure. 

The maximum amount does not apply where the meeting is held outside the UK in a European country where the national association is a member of EFPIA and thus covered by EFPIA Codes. In such circumstances the limits of the host country would apply.

Federal Law & Implementing Regulations, & Government-Issued Guidance: The laws and regulations do not specifically enumerate or define "appropriate" versus "inappropriate" standards regarding the provision of meals, but the situation in which they are offered is likely to impact the government’s perception of potential intent to induce or reward. In addition, the HHS-OIG Guidance specifically notes that companies providing benefits, including meals, in association with information or marketing presentations could potentially implicate the AKS.  The HHS-OIG Guidance states generally, with respect to entertainment, recreation, travel, meals, gifts, gratuities, and other business courtesies that the AKS should be considered and that “compliance with the PhRMA Code with respect to these arrangements should substantially reduce a manufacturer’s risk.”  68 Fed. Reg. 23,721, 23,738 (May 5, 2003). See below. HHS-OIG generally expects meals and refreshments to be reasonable and modest. Enforcement actions have cited kickbacks in the form of expensive dinners and excessive alcohol. 

State Laws & Implementing Regulations: States have varying approaches to meal limitations. For example, Vermont prohibits the provision of meals or other food items to Vermont HCPs or non-prescribing staff, unless the meals are fair market compensation for HCP services or refreshments at a convention booth.  Other states, like Massachusetts, limit the provision of modest meals for HCPs to in-office educational presentations and out-of-office speaker programs and conventions. 

Industry Codes of Conduct: The PhRMA Code permits modest, occasional meals if they are offered in the appropriate circumstances and venue. PhRMA’s Statement on Application of PhRMA Code Section 2 During Emergency Periods addresses the provision of meals in conjunction with virtual presentations to HCPs during the COVID-19 pandemic. Meals may only be provided if there is a reasonable expectation that the HCP will remain present throughout the event, and meals should continue to be limited to in-office or in-hospital settings. The AdvaMed Code provides that meals may only be provided to HCPs who attend and have a bona fide purpose for attending the meeting (e.g., no meals for entire office staff or guests).  Both the PhRMA Code and AdvaMed Code specifically warn against “dine & dash” programs offering meals without a company representative being present at the meeting.

Federal Law & Implementing Regulations, & Government-Issued Guidance: The laws and regulations do not specifically enumerate or define a maximum dollar value for meals, but the value is likely to impact the government’s perception of potential intent to induce or reward. In addition, the HHS-OIG Guidance specifically notes that companies providing benefits, including meals, in association with information or marketing presentations could potentially implicate the AKS.  The HHS-OIG Guidance states generally, with respect to entertainment, recreation, travel, meals, gifts, gratuities, and other business courtesies that the AKS should be considered and that "compliance with the PhRMA Code with respect to these arrangements should substantially reduce a manufacturer’s risk."  68 Fed. Reg. 23,721, 23,738 (May 5, 2003).  See below. HHS-OIG generally expects meals and refreshments to be reasonable and modest. Enforcement actions have cited kickbacks in the form of expensive dinners and excessive alcohol.  Federal guidance may also discuss limitations on meals for certain HCP interactions (e.g., OIG Special Fraud Alert on Speaker Programs notes a recent settlement involving instances where the average per attendee cost for food and alcohol at a speaker program exceeded $500).  

State Laws & Implementing Regulations: Some states incorporate concepts such as “modest” meals, with consideration of local standards, and gift caps which may come into play for meals depending on the circumstances.  For example, Minnesota sets an annual $50 cap, and Maine allows "modest" meals and refreshments of minimal value in certain circumstances and defines "modest" as the cost similar to that which an HCP would pay when dining at his/her own expense as judged by local standards where the event is held. Other states more generally incorporate PhRMA Code and/or AdvaMed Code standards by reference.

Industry Codes of Conduct: The PhRMA Code indicates that, in circumstances in which providing meals is otherwise appropriate under the Code, they should be modest as judged by local standards.  The AdvaMed Code also provides that permissible meals provided to HCPs must be modest and "provided in a manner conducive to the presentation of scientific, educational, or business information."

Federal Law & Implementing Regulations, & Government-Issued Guidance: The laws and regulations do not specifically enumerate or define "appropriate" versus "inappropriate" venues for meals, but the selection is likely to impact the government’s perception of potential intent to induce or reward.  In addition, the HHS-OIG Guidance specifically notes that companies providing benefits, including meals, in association with information or marketing presentations could potentially implicate the AKS.  The HHS-OIG Guidance states generally, with respect to entertainment, recreation, travel, meals, gifts, gratuities, and other business courtesies that the AKS should be considered and that "compliance with the PhRMA Code with respect to these arrangements should substantially reduce a manufacturer’s risk." 68 Fed. Reg. 23,721, 23,738 (May 5, 2003).  See below.  HHS-OIG generally expects meals and refreshments to be reasonable and modest. Enforcement actions have cited kickbacks in the form of expensive dinners and excessive alcohol. In addition to guidance more generally on appropriate venue and modest meals, advises against high-end restaurants. For example, OIG Special Fraud Alert on Speaker Programs said that suspect venues include high-end restaurants. 

State Laws & Implementing Regulations: In addition to guidance more generally on appropriate venue and modest meals, some states specifically include language mirroring the PhRMA Code in requiring that meals provided to health care providers generally must be provided in the provider's office or hospital setting. Some states more generally incorporate PhRMA Code and/or AdvaMed Code standards by reference. 

Industry Codes of Conduct: In addition to guidance more generally on appropriate venue and modest meals, the PhRMA Code states that sales representatives may provide meals in the HCP office or hospital only when provided in connection with an accompanying informational presentation and prohibits out-of-office meals by sales representatives or their immediate managers (except in connection with a speaker program). The AdvaMed Code provides that appropriate settings may include the HCP’s place of business "or an off-site space that is conducive to the discussion, such as a restaurant."