METHODOLOGY FOR DISCLOSURE OF BENEFITS BY CROSS PHARMACEUTICALS P.C. TO HEALTHCARE PROFESSIONALS (HCPs) AND HEALTHCARE ORGANIZATIONS (HCOs)
1. INTRODUCTION
Disclosure by Cross Pharmaceuticals P.C. of benefits in accordance with the provisions of Article 66, paragraph 7a of Law 4316/2014 (Government Gazette A' 270), which states that: “Each pharmaceutical company is required to disclose, by name, on its website and on the dedicated EOF website, no later than six months after the end of each calendar year, any benefit granted to third-party Healthcare Professionals and Healthcare Organizations […] in relation to the promotion of prescription-only medicines.” In line with this requirement, Cross Pharmaceuticals P.C. publishes on its website the attached list detailing the benefits granted to Recipients, namely HCPs and HCOs, during the 2024 calendar year (Reporting Period).
This webpage discloses the benefits provided by Cross Pharmaceuticals P.C. to Healthcare Professionals (HCPs) and the benefits provided to Healthcare Organizations (HCOs) for the period from 01/01/2024 to 31/12/2024.
The purpose of this Methodological Note is to analyze and provide clarifications regarding the content and rationale applied by Cross Pharmaceuticals P.C. in the disclosure of benefits, in accordance with Law 4316/2014 (Article 66, paragraph 7).
Disclosure Objectives:
Further promotion of transparency, professional ethics, and accountability
Clarity in the collaboration between HCPs/HCOs and pharmaceutical companies
Response to society’s growing demand for increased transparency and integrity
We explicitly state that the present disclosure of benefits to Healthcare Professionals has been prepared in accordance with Opinions No. 5/2016 and 2/2017 of the Hellenic Data Protection Authority, the content of which restricts nominal disclosure to promotional conferences aimed at the commercial promotion of prescription-only medicines. This disclosure also aligns with the relevant announcement issued by the National Organization for Medicines (EOF), which was published on the EOF website and is as follows:
Compliance check with Law 4316/2014 on the disclosure of benefits
Athens, 03.04.2024
In accordance with the principles of sound administration, good faith, and the legitimate trust of citizens—principles that govern the exercise of powers by public authorities—it is emphasized to those obliged to disclose benefits on their website and on the EOF website that the deadline set in paragraph 7 of Article 66 of Law 4316/2014 (Government Gazette A’ 270) is mandatory, namely “no later than six months after the end of each year,” and cannot be modified.
Therefore, the EOF's expense reporting and annual reconciliation service for the year 2023 will accept submissions through the EOF Online Application for Scientific Conferences until 30/06/2024 at 23:59. Moreover, any related updates sent by email or through the EOF General Secretariat will not be considered or evaluated.
Obligated entities are reminded that after the expiration of the above deadline, the Organization will conduct an audit to ensure compliance with paragraph 7 of Article 66 of Law 4316/2014 (Government Gazette A’ 270) and will impose the penalties provided by law to safeguard the public interest.
President of the National Organization for Medicines
Evangelos Manolopoulos
Professor of Pharmacology, Democritus University of Thrace School of Medicine
2. SCOPE OF APPLICATION
2.1 CATEGORIES OF RECIPIENTS
For the purposes of this Disclosure Form, the term "Recipients" refers to Healthcare Professionals (HCPs) and Healthcare Organizations (HCOs) who receive benefits from Cross Pharmaceuticals P.C. and whose main activity, professional address, or place of residence is located in Greece. Specifically:
2.1.1 Healthcare Professionals
Any natural person practicing medicine, dentistry, pharmacy, or nursing, or any other person who, in the course of their professional activity, is authorized to prescribe, dispense, or administer a pharmaceutical product. For clarity, the term “Healthcare Professional” includes:
(i) any executive or employee of a governmental body or other organization (whether public or private) who is authorized to prescribe, dispense, or administer pharmaceutical products, and
(ii) any employee of the Company who qualifies as an HCP and whose primary professional activity involves the provision of healthcare services.
Excluded from this category are:
(a) all private physicians who provide ongoing services to the Company under an employment, mandate, or project contract, and
(b) pharmaceutical wholesalers or distributors.
2.1.2 Healthcare Organizations
An HCO is defined as any legal entity that:
(i) is a healthcare, medical, or scientific association (e.g., scientific society or professional healthcare association) or a healthcare organization (regardless of its legal or organizational form), such as a hospital, clinic, foundation, university, or other educational institution or entity (e.g., NGO) that receives funding from pharmaceutical companies (excluding patient associations); or
(ii) through which one or more HCPs provide healthcare services, including private providers of Primary Healthcare Services (as defined in Presidential Decree 84/2001, Government Gazette 70/A/10.4.2001).
2.2 CATEGORIES OF BENEFITS
A "benefit" is defined as any transfer of value or rights, whether in the form of remuneration for services or sponsorship of educational activities or continuing education. It includes direct or indirect payments, in cash or in kind, made for promotional or other purposes, in relation to the development and marketing of generic or reference medicinal products for human use.
Direct transfers are those made directly by a pharmaceutical company for the benefit of a recipient.
Indirect transfers are made on behalf of a pharmaceutical company for the benefit of a recipient, where the identity of the company is known or can be reasonably identified by the recipient.
2.2.1 Benefits to Healthcare Professionals related to:
a) Participation in Events
Registration fees
Travel expenses
Accommodation costs
b) Fees for consulting and other services
Fees arising from or related to agreements between Cross Pharmaceuticals P.C. and HCPs under which services are provided, such as:
Training/education
Advisory seminars
Speeches/lectures
General consulting services
2.2.2 Benefits to Healthcare Organizations related to:
Donations (grants and sponsorships to HCOs supporting science, technology, medicine, healthcare, research, or education), which have been completed (i.e., invoiced and delivered to the beneficiary) within the reporting year.
Expenses related to scientific and/or educational events organized by HCOs for the training of Healthcare Professionals. For these expenses, the date of provision is considered to be the last day of the event.
Other sponsorships (e.g., website support).
When a third-party company organizes a conference on behalf of an HCO, Cross Pharmaceuticals P.C. discloses the sponsorship under the name of the beneficiary HCO, even if payment is made to the third-party company.
2.2.3 Research and Development Transfers of Value
Expenditures related to:
i) non-clinical studies,
ii) clinical trials, and
iii) prospective non-interventional studies
will be disclosed in aggregate form.
2.2.4 EXCLUSIONS FROM DISCLOSURE OBLIGATION
Benefits related exclusively to non-prescription medicines (OTC).
Items of negligible value directly related to medical practice.
Meals and beverages.
Benefits related to the purchase and sale of medicinal products.
3. DISCLOSURE OF FINANCIAL INFORMATION
3.1 Currency
All amounts are reported in euros (€). In cases where payments were made in a foreign currency, the exchange rate in effect on the invoice date was used to convert the amount into the national currency.
3.2 VAT and Other Taxes
The disclosed benefits include, where applicable, Value Added Tax (VAT), Withholding Income Tax, any applicable deductions in favor of ELKE/ELKEA/RHAs/third parties, and other charges, as reflected in the relevant official supporting documentation.
4. TIME OF DISCLOSURE
The publication of information regarding transfers of value to HCPs and HCOs is carried out on an annual basis. All data is recorded throughout the year and is published no later than the end of the first half of the following year. Access to the disclosed information will remain available for a period of three years.
5. DISCLOSURE RECORD
The record is published today, 27/06/2025, on the website of CROSS PHARMACEUTICALS P.C. (http://www.crosspharma.gr) for the year 2024, in accordance with the applicable legislation.