Code of Ethics Notice
INTRODUCTION
Giuliani is a member of Farmindustria, which complies with the statutory provisions and the rules established by EFPIA (European Federation of Pharmaceutical Industries and Associations) and IFPMA (International Federation of Pharmaceutical Manufacturers & Associations), the international federation representing the innovative pharmaceutical industry worldwide.
This membership represents a voluntary agreement among Italian pharmaceutical companies aimed at regulating relations between the pharmaceutical industry and the Italian scientific and healthcare communities.
In compliance with the EFPIA Code and the Farmindustria Code of Conduct, Giuliani is committed to documenting and annually disclosing transfers of value made directly or indirectly to healthcare professionals (HCPs), healthcare organizations (HCOs), patient associations, and expert patients.
The publication of transfers of value is intended to ensure transparency and ethical conduct in the interaction between the pharmaceutical industry and healthcare professionals; a transparent approach helps strengthen public trust in the pharmaceutical sector.
These transfers are summarized and reported in a dedicated form prepared by Giuliani and published annually by June 30 on the corporate website, www.giulianipharma.com.
WHAT TRANSFERS OF VALUE ARE
Transfers of value are any payments or benefits, either monetary or in kind, provided by a pharmaceutical company to a healthcare professional (HCP) or a healthcare organization (HCO).
The following activities fall within this category:
* Participation in events such as congresses and conferences.
* Consultancy and professional services.
* Donations and contributions.
* Research and development activities, including clinical, non-clinical, and observational studies.
Transfers may be direct (provided directly by the company) or indirect (provided through third parties, such as service providers).
Collected data may be published either in aggregated form or on an individual basis.
In order to publish, on a named basis, data relating to Transfers of Value made in favor of HCPs, Giuliani is required to comply with personal data protection and processing legislation (EU Regulation No. 679/2016 and Legislative Decree No. 196/2003, as amended). Therefore, prior consent for publication is obtained by submitting to the data subject the form entitled “Transparency.” If the healthcare professional has not provided consent, the contribution will be included in aggregated values.
Data Collection Methods
By June 30 of each year, Giuliani collects all relevant information regarding contributions made to HCPs and HCOs during the previous calendar year.
Reporting is carried out according to the accrual accounting principle, meaning that transfers of value are recorded in the period in which they accrue, regardless of when the cash payment is made.
The amount of transfers of value is indicated net of VAT and gross of withholding tax.
Reports will remain available for at least 3 years from the date of publication.
Consent for the publication of personal data obtained from healthcare professionals is valid for one year and must be renewed for each publication. If consent is not renewed, the amount of the contributions will be included in aggregated values.
Collaboration between pharmaceutical companies and physicians covers several areas of activity:
* Research and development of new medicines through clinical studies carried out in hospitals, universities, and public and private healthcare facilities;
* Scientific consultancy services;
* Scientific seminars and conferences providing information and professional updates;
* Support for congresses and CME (Continuing Medical Education) courses organized by public institutions, universities, scientific societies, and accredited CME providers.
Documentation supporting the published data is retained by Giuliani for at least five years and is made available upon request.
As specified in the Farmindustria Code of Conduct, certain transfers of value are excluded from publication obligations, such as those relating to OTC medicines, promotional materials, meals, beverages, and free samples.
TRANSFERS OF VALUE FOR HEALTHCARE PROFESSIONALS (HCPs)
Giuliani publishes, on an individual basis for each recipient, the amount of transfers of value made during the previous year relating to:
• Participation expenses for conferences and congresses:
* Registration fees
* Accommodation (excluding meals)
* Transportation
Please note that transfers of value relating to “No show” cases or booking cancellations will not be published.
In 2025, transfers of value related to the participation of HCPs in events promoted by Giuliani were published in aggregated form.
• Fees for professional services and consultancy:
* Compensation
* Expenses related to consultancy activities and professional services arising from a specific contract, including related travel and hospitality expenses
In 2025, transfers of value relating to professional consultancy services were published individually and explicitly, subject to the consent of the interested parties.
TRANSFERS OF VALUE FOR HEALTHCARE ORGANIZATIONS (HCOs)
Giuliani publishes the amount of transfers of value made to each Healthcare Organization during the previous year relating to:
• Expenses for congress and conference events:
* Direct or indirect funding of congress events
* Sponsorship of HCPs for conferences and congresses:
. Generic registration fees (not assigned by Giuliani)
. Accommodation (excluding meals) and transportation for participants not identified by Giuliani
. Sponsorship agreements
• Fees for consultancy and professional services (e.g., speakers)
• Expenses related to consultancy activities arising from a specific contract, including related travel and hospitality expenses
• Donations or contributions (loan-for-use agreements and scholarships)
In 2025, transfers of value made to HCOs were published in aggregated form.
RESEARCH EXPENSES
Transfers of value relating to the planning and execution of research studies fall within transparency requirements in the following cases:
• Non-clinical research studies (as defined by Good Laboratory Practice)
• Clinical research studies as defined by Directive 2001/20/EC (including related consultancy services aimed at conducting clinical studies)
• Prospective observational studies referred to in section 4.4 of the Code of Conduct, involving the collection of patient data by individual physicians or groups of physicians
• Investigators Meetings
• Advisory Boards (technical consultancy aimed at research and development)
• Expenses related to consultancy activities arising from a specific contract, including related travel and hospitality expenses
These expenses are published in aggregated form.
