Voluntary disclosure of payments

As part of our commitment to high ethical standards and enhancing trust, Innovative Medicines Canada has developed a Voluntary Framework on Disclosure of Payments made to healthcare professionals and/or organizations in exchange for services and to fund charitable, educational and scientific activities.Collaboration between healthcare professionals, healthcare organizations and the pharmaceutical industry is essential to improving the quality of life of Canadians as it drives scientific advancements, enhances medical education, and promotes health literacy.

Starting in June 2017, 10 Canadian pharmaceutical companies – all of them members of Innovative Medicines Canada – will begin publishing aggregated sums of their payments to Canadian healthcare professionals (HCP) and healthcare organizations (HCO) based on the following reporting framework:

    • One sum total of the company’s payments to HCPs for services such as speaking and/or consulting.
    • One sum total of the company’s funding to HCOs, which supports efforts such as philanthropic (charitable), educational and/or scientific activities.
    • One sum total of the company’s funds provided to HCPs to support their travel to attend international congresses and/or global standalone meetings.

There are currently 10 voluntary disclosing member companies:

  1. AbbVie Corporation
  2. Amgen Canada Inc.
  3. Bristol-Myers Squibb Canada
  4. Eli Lilly Canada Inc.
  5. Gilead Sciences Canada, Inc.
  6. GlaxoSmithKline Inc.
  7. Hoffmann-La Roche Limited (Roche Canada)
  8. Merck Canada Inc.
  9. Novartis Pharmaceuticals Canada Inc.
  10. Purdue Pharma (Canada)

Voluntary Framework on Disclosure of Payments

The Voluntary Framework on Disclosure of Payments provides members of Innovative Medicines Canada with a framework to publish aggregated sums of payments to Canadian healthcare professionals (HCP) and healthcare organizations (HCO).


In considering the types of activities/categories whereby member companies would disclose aggregated payments, it was decided that disclosure would take place in the following areas:

1. Fee for healthcare professional services/transfer of value to Canadian healthcare professionals

Any direct or indirect payment made to a Canadian HCP by a Canadian Innovative Medicines Canada member company or a third party acting on behalf of the member company, in exchange for services rendered by said HCP to the Canadian member company. Such services may include services rendered as a speaker, consultant or advisor to the Canadian member company. Consistent with the current Code of Ethical Practices, a HCP is defined as, “… a person who by education, training, certification, or licensure is qualified to and is engaged in providing healthcare. This can include any of the following: an individual who is currently practicing medicine, nursing, or dispensing medicines in Canada or any other person who, in the course of his or her professional activities, may prescribe, recommend or administer a prescription medicine or be involved in related treatment or disease management.”

For greater certainty, a direct or indirect payment to a Canadian HCP payment is defined as:

  • A payment to the HCP as an individual.
  • A payment to an HCP’s incorporated name or business name for services rendered by that HCP.
  • A payment indirectly to the HCP through a third-party intermediary.
  • A payment made to a healthcare organization for services rendered by an HCP associated with or employed by the healthcare organization.

Members companies should be prepared to disclosure the aggregated totals of fee for service. Dependent upon the member company’s system and reporting capabilities, these totals may or may not include applicable taxes as well as related incidental expenses. Member companies are encouraged to include explanatory notes on the respective website so as to describe and explain the amounts disclosed. For instance, a member company whose systems do not allow the extraction of applicable taxes may include an explanatory note to the effect of, “*taxes included.” Payments made for services, as defined herein, rendered by a Canadian HCP for an international affiliate of the Canadian member company would not be considered in scope for this framework.

2. Funding to healthcare organizations

Any direct or indirect provision of funding to a HCO for the purpose of supporting efforts related to, but not limited to, charitable, educational, and scientific activities. For the purpose of this framework, a HCO is defined as a private or public sector organization, institution or association that is comprised of HCPs and/or provides healthcare services (e.g. hospitals, primary care organizations, hospital foundations, HCP organizations and universities).

This provision of funding excludes:

  • Funding resulting in a purchase/exchange of goods or services, such as commercial booths or business to business/partnership agreements.
  • All funding related to clinical trials.
  • Payments made to a Canadian HCO for services rendered by a HCP and which have been disclosed under category 1, “Fee for healthcare professional services/transfer of value to Canadian healthcare professionals.”

3. Sponsorship of Canadian healthcare professionals travel

A direct or indirect provision of financial assistance to a Canadian HCP for the purpose of attending an international congress (as permitted under Sections 10.2 of the Code of Ethical Practices). Such funding is intended for expenses related to travel, accommodation, meals and congress registration fees (as permitted by the Code) and does not include any honoraria or fee for service.