1. PURPOSE & SCOPE
This Policy of IAMEX S.A. concerns the Provision of Sponsorships at Scientific Events as well as any form of Donation and applies to all the following activities and transactions for all the Company's staff and partners.
• Scientific Events (Conferences) from scientific bodies, domestic and foreign • Educational Events (Seminars) from scientific or industrial bodies • Donations to Organisations/ Health Professionals • Grants for medical Education, Information and Research
2. AUTHORITIES
2.1. General Manager 2.2. YSDD
3. DESCRIPTION
IAMEX SA laying a strong foundation of integrity and compliance with the rules of Ethical Business Practice, has adopted and incorporates into this Policy the following Codes of Ethics of industry associations to guide employees in making sound, ethical business decisions and actions.• Code of Ethical Professional Practice of the Medical Business Association & Biotechnological Products (SEIB) • Code Ethical Business Practice of MedTech Europe (European trade association of the medical technology industry)
4. SPONSORS
General Principles of Sponsorship
The company IAMEX S.A. in the context of good cooperation with the scientific world, but also in the context of supporting more complete education of the scientific community, it can participate through sponsorships in scientific conferences and informative seminars of its clients or other scientific bodies. However, the following conditions and rules established by the above codes of ethics as well as by the competent state authorities (EOF) and in accordance with the 37201/23.03.2020 Circular of the EOF for Scientific Events must be strictly observed.
Terms & Conditions of Sponsorship:
1. Scientific nature of the event
The Company can finance scientific events (Conferences, Symposia, Seminars, Conferences, etc.), in Greece and abroad, whose program has a purely scientific content. The events can be organized by state institutions, such as universities, state hospitals, as well as by scientific clubs and scientific associations of any kind. The Company can organize scientific information events, in the form of seminars, workshops and other similar events, with the aim of wider scientific information. These events are held in collaboration with scientific associations, scientific councils of hospitals and scientific societies, in order to ensure the possibility of participation of every interested scientist.
2. Approval of financing by a competent authority (EOF)
A condition for the legal financing of scientific events is that the organizer of the event must have previously submitted an application to the EOF and received the relevant organization permit.
3. Product Promotion Events
IAMEX can organize, at its own expense, events to inform and promote its products, both in Greece and abroad, with the main focus being transparency in information and the completeness of information, however, NHS doctors and medical staff are not invited to these events. university doctors, who work in clinics located in NHS hospitals since they are expressly prohibited by the E.O.F.
4. Program of Events
The program of the Events should be directly related to the specialty and/or medical practice of the Health Professionals who will attend the Event, or be relevant enough to justify the participation of the Health Professionals. For Educational Events organized by Third Parties, the program shall be under the sole control and responsibility of the Organizer.
IAMEX cannot organize Events that include social, sports or other forms of Entertainment nor support such events when they take place at Educational Events organized by Third Parties.
In the context of Educational Events organized by Third Parties, the entertainment must be outside the educational program and paid for by the Health Professionals themselves. Entertainment should not dominate or influence the overall scientific content of the program and should take place at a time that does not overlap with scientific sessions. Entertainment should not be the main attraction of the Educational Event.
5. Location of Event
The location and venue of the Event should not be the main attraction of the Event. For the place and space, IAMEX must in any case take into account the following:
• Perceptions of public opinion about the place and venue of the Event. The perception of the place and the space should not be intertwined with luxury, with tourism and holidays or places of Entertainment. .• The place and venue of the Event should be in or near a city or town recognized as a scientific or business center suitable for hosting an Event which favors the exchange of ideas and the transmission of knowledge.• The selected time of year should not be linked to a tourist season, for the selected geographical area.
6. Coverage of Participation Expenses
IAMEX is allowed to cover the participation costs of Health Professionals and specifically the costs for the registration, travel, accommodation and food of the participant at reasonable levels and on the condition that the Health Professional has received the relevant educational permit from his employer. IAMEX is not permitted to facilitate or pay for travel, accommodation, meals or other expenses for persons invited by the Healthcare Professionals, or for any other person who does not have a legitimate professional interest in the information presented at the Event.
7. Reasonable Accommodation
IAMEX can provide reasonable hospitality to Health Professionals in the context of Corporate Events and Educational Events Organized by Third Parties, however any hospitality offered must be proportionate to the duration and purpose of the Event.
• The Company should in all cases meet the requirements governing hospitality in the country where the Healthcare Professional works, and take into account the requirements in the country where the Event is hosted.• The Company should maintain a balance between courteous on the one hand and professional treatment of Health Professionals on the other hand in order to avoid the image that hospitality can be used as a challenge to Health Professionals in order for them to buy or recommend the Company's products. • The Company must assess what is "reasonable" in any given situation. As a general guideline, "reasonable" should be interpreted as the appropriate standard for the particular location and should comply with national laws, regulations and professional codes of conduct. • The term "hospitality" includes meals and accommodation and it is important that the Company differentiates "hospitality" which is permitted from "Entertainment" which is not permitted.• Accommodation and/or other services provided to Healthcare Professionals must not cover period of stay beyond the official duration of the Event.• The Company cannot pay or cover the expenses of Health Professionals for staying in luxury hotels. If the event is held at a hotel that meets the requirements of the code, the Company may provide participants with meals and lodging at the same hotel.
8. Travel
IAMEX can only pay or cover reasonable and actual travel and only for the travel and return of Healthcare Professionals to the venue of the Event.
• Travel provided to Healthcare Professionals should not cover a period of stay beyond the official duration of the Event.• For air tickets, the Company can only cover economy class, unless the travel duration is more than 5 hours including connecting flights. In this case the distinguished position (Business) can be filled. The first position is not allowed. • For ferry tickets, the Company can only cover economy class, unless the journey is longer than 5 hours. In this case the position in a cabin can be filled.
• The Company does not allow for any reason the financial coverage of the cost of tickets, accommodation and meals of the accompanying members of the Health Professionals.
9. Online Events
IAMEX can sponsor the participation of Health Professionals in online scientific events via the Internet (individual or group), by providing access codes for continuing education, through the use of technology.
10. Honorarium
IAMEX may pay an honorarium to invited speakers or round table chairpersons, as long as it is in accordance with the provisions of article 36 par. 18 N. 4272/2014
11. Limits on the Number of Participations
The maximum number of participants that IAMEX can cover per scientific event is as follows:A) For Domestic Scientific Events/conferences > There is no participation limitB) For Scientific Events/conferences within Europe > Up to ten (10) Health Professionals/per conferenceC) For Scientific Events/conferences outside Europe > Up to five (5) Health Professionals/per conference
12. Expenditure Limits
Sponsorship Spending Limits
IAMEX is allowed to sponsor scientific events depending on their duration up to the following maximum sponsorship amounts:A) For Panhellenic Conferences with a program duration of more than two (2) days > the sponsorship amount can be up to €30,000B) For Scientific Days/Two-Days with a program duration of one (1) to two (2) days > the sponsorship amount can amount to €5.000C) For Scientific events with a program duration longer than eight (>8) hours > the sponsorship amount can be up to €15.000
Hospitality Expense Limits
IAMEX is allowed to cover the cost of hospitality (accommodation and food) of Health Professionals at scientific events up to the following maximum amounts:
A) For Indoor Scientific Events/conferences > Cost of accommodation and food per day up to the amount of €70 and €150.00 respectively, including VAT and accommodation tax. B) For Scientific Events/Conferences Abroad > The cost of accommodation per day is divided into o Higher cost of meals with breakfast up to €150.00 including VAT and o Higher cost of accommodation up to €400.00 including VAT
Expense Approval
For any type of sponsorship, the Expense Approval procedure is applied as follows using Form E.32-1.
5. DONATIONS
General Principles of Donation
The company IAMEX S.A. in the context of social responsibility actions, it can support charitable organizations through a Donation of either money or property. However, it should be ensured that donations of a charitable and social nature will be offered to recognized organizations, after relevant research and evaluation, without any expectation of obtaining any business advantage or other preferential treatment in return.
Donation Terms & Procedure
• Donations must in no way be linked to the sale, recommendation, prescription, use, offer or supply of IAMEX products or services. The support of IAMEX's benevolent and/or charitable activities should not be treated as a reward to select customers or as an incentive for the purchase, or suggested prescription, use, or supply of IAMEX products and services.• Donations may not be provided to individual Health Professionals. Donations must be made directly to accredited, eligible organizations or entities.• Charitable Donations may only be made to charities or other non-profit organizations that have a benevolent or charitable purpose as their primary purpose and that are objectively engaged in with genuine benevolent or charitable activities.• Limited Charitable Donations to non-profit hospitals are allowed in case of proven Financial Difficulty and when Charitable Donations serve exclusively the benefit of the patient and when expressly permitted by applicable national law. Donations should not be provided in response to requests from Healthcare Professionals, unless the Healthcare Professional is an employee or representative of the accredited organization or entity and submits in writing in its application that it is operating on behalf of the organization or entity that meets the conditions.• The payment of the Donation must always be made in the name of the beneficiary organization and be paid directly to the organization and in no case to the name of each Health Professional. • All Donations will identify IAMEX as the provider of the Donation.• The Donation must be legal in accordance with applicable national laws and regulations, and the recipient will benefit from the specific type of Support or Charitable Donation.• The Company may to make unlimited Charitable Donations, for sincere noble or other charitable purposes. "Unrestricted" means that the Company has no control over the final use of the Donation amount other than general restrictions to ensure that the amounts (or other support) are used for good and/or charitable purposes.
PROCEDURE
Donations are provided in response to a written request submitted by the requesting organization or following a documented initiative by the Company that contains sufficient information to enable an objective evaluation of the request. All Donation decisions must be properly documented by the Company.
For the approval and payment of the Donation:
1. An extraordinary meeting of the Board of Directors is held where the Donation request is examined and an independent decision-making process is applied to identify and prevent the potential risks of bribery that may arise by providing the Donation to a specific prospective recipient. 2. If the Donation is deemed lawful and in accordance with this Company Policy, the Board of Directors issues a certificate of approval of the Donation. 3. Next, a certificate of acceptance is issued by the recipient of the Donation which is sent to the recipient and signed by both parties.
All Donations should apply:
• Division of duties, so that the payment is not approved by the same person who proposes it • Periodic checks and review of important financial transactions by the accounting officer (control of approvals and records).
6. GRANTS
1. Educational Scholarships and Specialization Scholarships
The Company IAMEX S.A. may provide Educational Grants on a limited basis, in the form of Grants for Educational Scholarships and Scholarships to support the development of genuine medical education, of Health Professionals. Only Healthcare Organizations where Healthcare Professionals are trained may apply for and receive such Educational Grants.
The Company cannot provide Educational Grants, to support Educational Scholarships and Specialization Scholarships after applications of individual Health Professionals. Also, the Company will not have any involvement in the selection of Health Professionals who will benefit from the Educational Support and this will be reflected in the written sponsorship agreement between the Company and the recipient Health Organization.
2. Grants for the Public Awareness Campaign
The Company IAMEX S.A. may provide Educational Grants on a limited basis, to Healthcare Organizations, with the legitimate purpose of providing information, promoting awareness and/or informing patients, caregivers or the general public, on issues related to healthcare or medical conditions in therapeutic areas in which the Company operates.
3. Research Funds
Where permitted by national legislation, the Company IAMEX S.A. may provide limited Research Funds to support clearly defined research studies conducted by Third Parties for clinical or non-clinical research programs in therapeutic areas in which the Company operates. Research Funds may be given in kind or through financial support for legitimate, documented expenses or services, and/or reasonable amounts of materials without charge for the duration of the research. The Company should ensure that the Funds are provided on a "limited" basis.
In addition, the Company must clarify the purpose of the research and the scope as well as the purpose for which the Fund is requested and be ensured by a written Sponsorship Agreement with the recipient organization. All applications for Research Funds from prospective recipients of Research Funds must be made in writing and must describe in detail the type, nature and objectives of the research activity, the budget, the duration of the research.
The Company will be able to make a final decision on the Support application only after the research has received formal ethics committee approval.
7. FILES
Records of the above forms are kept by YSDD for 5 years.
Documents: 32-1 Expenditure Authorization Form
External Documents: 1. MedTech Europe Code of Ethical Business Practice MedTech Europe Code of Ethical Business Practice 2. SEIB Code of Ethical Professional Practice 3. Circular EOF Min. No. Prot. 37201/23.03.2020 for Scientific Events
8. HISTORY OF THE DOCUMENT
Ed. Date Description of Change Version From1 15/07/2024 Initial Version YSDD