The relationships between industry and healthcare professionals, or HCPs, and healthcare organizations, or HCOs, provide invaluable benefits to the advancement of modern medicine. As global healthcare has evolved, public interest in the nature of these relationships has grown along with public interest in understanding whether any potential conflicts of interest may arise as well. In response, a worldwide trend has been launched among various countries and industry groups to establish requirements for companies to disclose transfers of value made to HCPs and HCOs.

Bristol-Myers Squibb believes in fostering an open environment to help build a foundation of trust, credibility, and respect among our colleagues, healthcare providers, patients, stockholders, and the public. Bristol-Myers Squibb further believes that interactions with individuals and institutions in the healthcare delivery system should take place in an open, honest, and ethical manner. These interactions should be based on the pursuit of objective science and the communication of scientifically accurate information, and relate to matters that are important to healthcare providers and patients.

Our company is committed to working in partnership with others in a way which is fully compliant with Innovative Medicines Canada Code of Ethical Practices as well as the Voluntary Framework on Disclosure of Payments to Health Care Professionals and Health Care Organizations. We support financial disclosure laws and codes as an extension of our own efforts to increase public awareness of the positive collaboration between industry and HCPs/HCOs.

 Please use the links below for further information:


Innovative Medicines Canada Code of Ethics


Frequently Asked Questions about Innovative Medicines Canada Voluntary Framework

What is Innovative Medicines Canada?

Innovative Medicines Canada represents more than 50 companies all of whom are revolutionizing healthcare through the discovery and development of new medicines and vaccines. Innovative Medicines Canada and its members have set a high standard for ethical, transparent and open practices that respect the relationships between our member company employees, the life sciences sector, healthcare professionals and the Canadian public.

What are the specifics of the Innovative Medicines Canada Voluntary Framework?

Innovative Medicines Canada has developed a Voluntary Framework on Disclosure of Payments made to healthcare professionals/organizations in exchange for services and to fund charitable, educational, and scientific activities.

Member companies who opt to disclose payments will record and report their respective payments to healthcare professionals/organizations. Those implementing the Voluntary Framework will start to capture payment data in 2016 and begin disclosure in 2017.

Innovative Medicines Canada Voluntary Framework on Disclosure or Payments

Why is there a need for a Voluntary Framework?

By creating greater transparency around industry’s collaborations and partnerships with HCPs/HCOs, the Framework aims to strengthen the legitimate relationship between pharmaceutical companies and healthcare professionals by making these better understood by patients and other stakeholders.

Why do we work with Healthcare Professionals?

Healthcare professionals and pharmaceutical companies regularly work together, from early scientific research and clinical trial programmes to the use of medicines in the patient pathway. As an integral part of the medicines development and ongoing clinical review process, it is entirely appropriate that fees be paid to healthcare professionals to reimburse them for their time and expertise.

Bristol-Myers Squibb engages Consultants for services required to fill a legitimate business or scientific need of the company. They are used where requisite resources or expertise may not be available from other sources and have not otherwise been provided.

Patients benefit from such collaboration through the continued development and use of innovative treatments and guidance that can improve and extend life.

What is the definition of healthcare professional in the context of the Innovative Medicines Canada Voluntary Framework?

The term Health Care Professional means a person who by education, training, certification, or licensure is qualified to and is engaged in providing health care. 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.

What is considered a Transfer of Value under the Framework?

Each member company must disclose any transfers of value in aggregate listed below that it makes to or for the benefit of an HCP or HCO in Canada. Direct and indirect transfers of value, whether in cash, in kind or otherwise, made, whether for promotional purposes or otherwise, in connection with the development and sale of prescription-only Medicinal Products exclusively for human use are reportable.

What are direct transfers of value?

These are transfers that are made directly by a Member Company for the benefit of a Recipient.

What are indirect transfers of value?

These refer to transfers that are made on behalf of a Member Company for the benefit of a Recipient, or transfers of value made through an intermediate and where the Member Company knows or can identify the HCP/HCO that will benefit from the Transfer of Value.

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 Health Care Organization (HCO) for services rendered by an HCP associated with or employed by the HCO

Which activities would be reported by companies?

The following activities would be reported by companies in aggregate for direct or indirect payments of transfer of values made to healthcare professionals for services:

  • Speaker fees, honoraria, consultations, advisory boards, etc.

  • Grants, donations, sponsorships

  • Sponsorship of healthcare professional travel

What Transfers of Value are excluded from the Voluntary Framework?

  • Funding to patient groups

  • Clinical trials

  • Meals and refreshments

  • Market research (double blind studies)

  • Samples

  • Payments to Canadian healthcare professionals made by a company’s international affiliates

What information about healthcare professionals will be reported and published?

Member companies who choose to implement the Framework will record and disclose payments in aggregate fashion. Canadian privacy law protects individual doctors’ information. In order to proceed in full compliance with Canadian privacy requirements, specific amounts will not be associated with individual recipients, and recipients’ names will not be published.


Disclosure Reports

Disclosure Report

Bristol-Myers Squibb has prepared the report for publication in accordance with the Innovative Medicines Canada Voluntary Framework.

If you have a question about transactions reported by Bristol-Myers Squibb,contact us at: