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Meals and Educational Items

Bausch + Lomb allows the provision of modest meals to healthcare professionals (HCPs) when these meals accompany product-related presentations or discussions that offer scientific or educational value. Meals may also be provided to HCPs involved in contractual arrangements, such as Advisory Boards. This policy applies whenever an HCP is present at a meal with a Bausch + Lomb colleague.
All interactions with HCPs should focus on educating them about Bausch + Lomb products or disease states, conducting business communications such as contract negotiations, providing scientific and educational information, and supporting medical education.
Meals must never be used to solicit business or to create an expectation of gaining a business advantage. They should never imply that the recipient was improperly influenced by receiving the meal.
Business meals should be occasional and directly linked to an educational presentation or business discussion.
All value provided to an HCP, including snacks, must be accurately recorded following internal procedures. This includes the full cost of the meal—food, beverages, taxes, tips, and delivery fees—as well as properly identifying all HCP attendees, including those not involved in patient care (e.g., HCPs employed by managed care organizations). Additional expenses such as room rental, or audiovisual equipment fees are excluded from the transfer-of-value calculation.
Business meals offered by field sales colleagues who promote or sell pharmaceutical products, or their immediate managers, should be provided only in in-office or in-hospital settings or as part of an out-of-office Speaker Program. This rule applies to anyone regularly involved in selling or promoting pharmaceutical products who reports to the head of sales or is compensated as part of the sales function.

Quick Tips:

  • The primary purpose of any meal between Bausch + Lomb Colleagues and HCPs should be a substantive educational or business discussion.
  • A business meal or Educational Item may never be provided in order to induce or to reward an HCP for prescribing, purchasing or recommending Bausch + Lomb products.
  • A modest in-office or in-hospital meal with an HCP should not exceed $25 per person for breakfast, lunch or dinner, or $5 per person for snacks. These amounts include tax, tip and delivery charges.
  • Where appropriate, a modest out-of-office or hospital meal with an HCP not associated with a Speaker Program should not exceed a per- person cost of $35 for breakfast, $55 for lunch or $150 for dinner. These amounts include tax, tip and delivery charges.

This restriction does not apply to sales colleagues promoting only medical device products or to certain other corporate-approved teams, such as Managed Market Account Managers. For these colleagues, out-of-office meals are allowed only when the healthcare professional’s office is unavailable or unsuitable for an educational or business discussion.
Corporate Commercial Functions may conduct modest offsite business meals when appropriate. Please consult Compliance for further details.
Some states have specific laws that prohibit or limit the provision of meals and other items of value to healthcare professionals, state government employees, or members of State Formulary Committees.
Colleagues working in states with such regulations must adhere to the applicable state laws and follow guidance from their managers. For more information, please refer to the Summary of Healthcare Laws guidance.

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In-Office Meals

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Out-Office Meals

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Educational Items