Disclosure of Transfers of Value made to Healthcare Professionals (HCPs) and Other Relevant Decision Makers (ORDMs) whose principal place of practise is in the UK or Ireland

In respect of any transfers of value that Eisai has agreed to make to an HCP or ORDM whose principal place of practise is in the UK or Ireland (such as for an HCP/ ORDM’s participation in a meeting (e.g. any speaker honorarium), or where Eisai has agreed to pay any expenses of an HCP/ ORDM which are required and necessary for that HCP/ORDM to attend a meeting), Eisai, as data controller, will disclose to the Association of the British Pharmaceutical Industry (ABPI) or the Irish Pharmaceutical Healthcare Association (IPHA), as applicable, the name of the applicable HCP/ ORDM, their professional/ principal practice address and the details and type of the transfers of value made to that HCP/ ORDM (“Personal Data").

To disclose the HCP/ ORDM’s Personal Data to the ABPI or IPHA, as applicable, Eisai relies upon the lawful basis of pursuing its legitimate interests to comply with Eisai’s obligations under and the objectives of the ABPI Code or IPHA Code, as applicable. This is to help support increased transparency and accountability in the interactions and relationships between pharmaceutical companies and HCPs, ORDMs, and Healthcare Organisations (HCOs) and so build and maintain confidence in these interactions as well as reducing any perception of conflicts of interest in such interactions. An HCP/ ORDM has the right to object to Eisai processing their Personal Data in this manner by writing to Eisai at: Eisai_UK_ROI_disclosure@Eisai.net and including the reason (s) for their objection so Eisai can consider their objection.

Further information for HCPs and ORDMs on how Eisai uses their Personal Data, and their rights can be found at www.eisai.eu/privacy-policy/ Eisai’s Data Protection Officer can be contacted at
Data_Protection_EMEA@Eisai.net

Use of an HCP/ ORDM’s Personal Data by the ABPI or IPHA, as applicable

Disclosure by the ABPI - The ABPI will make a public disclosure of the transfers of value details provided by Eisai through the Disclosure UK database hosted on its website. This could include elements of an HCP/ ORDM’s Personal Data, and Eisai’s identity as the payer. The ABPI may also use the data transferred to it by Eisai to:

1. contact the HCP/ ORDM to verify the accuracy of this data, and the HCP/ ORDM may query this data or opt-out of the publication of this data;
2. perform statistical analysis on the data provided;
3. inform the ABPI’s engagement with the media around the transparency initiative of the ABPI; and/or
4. anything else reasonably necessary for the purposes of the ABPI’s transparency work, including monitoring Eisai’s compliance with the ABPI Code.

Pursuant to the ABPI Code, Eisai is required to document all transfers of value required to be disclosed and maintain the relevant records of the disclosures for a minimum of 5 years after the end of the relevant reporting period. The transfer of value disclosures will be publicly available for a period of 3 years after publication on Disclosure Search (disclosureuk.org.uk) after which they will be deleted by the ABPI.

The ABPI’s contact details and privacy notice can be found at www.abpi.org.uk/contact-us

Disclosure by the IPHA - where an HCP/ ORDM’s Personal Data will be provided to the IPHA pursuant to the IPHA Code, the IPHA will be an independent data controller in respect of the HCP/ ORDM’s Personal Data which is hosted and made publicly available on the IPHA website www.transfersofvalue.ie. The IPHA will, in addition to Eisai, process the HCP/ ORDM’s Personal Data on the lawful basis of pursuing its legitimate interests in doing so, namely to (i) decrease any perception of influence on HCPs by the pharmaceutical industry; (ii) promote a culture of integrity of transactions between pharmaceutical companies and HCPs; (iii) increasing public and patient confidence in the integrity and independence of HCPs (itself essential for generating confidence in those relationships and their proper functioning); (iv) ensure compliance by the pharmaceutical industry with legislative and Code restrictions in relation to advertising and promotion; (v) demonstrate transparency in relation to the industry’s relationships with HCPs; (vi) show accountability in these relationships and compliance by the industry and HCPs in relation to their legal obligations not to provide (on one hand) or accept (on the other hand) inducements to prescribe; (vii) promote confidence on the part of the public and on the part of stakeholders (e.g. regulators, managers of public health services, Government) in the legitimacy and bona fides of the engagements between the industry and HCPs; and (viii) provide assistance in avoiding conflicts of interest.

An HCP/ ORDM has the same rights against IPHA for where the IPHA acts as data controller, and further information is provided at www.dataprotection.ie/en/individuals

Pursuant to the IPHA Code, Eisai is required to document all transfers of value required to be disclosed and maintain the relevant records of the disclosures for a minimum of 5 years after the end of the relevant reporting period. The transfer of value disclosures will be publicly available for a period of 3 years after publication on www.transferofvalue.ie, after which they will be deleted by the IPHA.

The IPHA can be contacted at 7 Clanwilliam Terrace, Dublin 2, D02 CC64, by telephone on (353 1) -661 0018, and by email on info@ipha.ie The IPHA’s privacy notice is available on www.ipha.ie. Any processing of the HCP/ ORDM’s Personal Data by the IPHA will be supervised by the Irish Data Protection Commission, who can be contacted on 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland or via the webforms available at www.dataprotection.ie/en/contect/how-contact-us