Business Meals

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.

It is appropriate to provide occasional in-office or in-hospital meals to healthcare professionals (HCPs) and their staff attending presentations, provided the presentations offer scientific or educational value. An in-office meal may include any consumable items such as refreshments, snacks, or a cup of coffee. These modest food items should be reasonably expected to be consumed during the presence of a Bausch + Lomb sales colleague and are not intended to stock the office before or after a visit. Offering an occasional beverage, snack, or meal is acceptable as long as the quantity is consistent with what would typically be consumed during a standard sales visit. For instance, providing a modest amount of coffee to accompany a breakfast or lunch program is appropriate, but supplying the office with ongoing coffee provisions is not permitted.

The cost of a modest in-office or in-hospital meal should not exceed $25 per person for breakfast, lunch, or dinner, or per person for snacks. This limit includes incidental expenses such as tax, tip, and delivery. Note that snacks do not count toward the limit on the number of meals provided to an HCP.

Alcohol is not allowed during in-office or in-hospital meals, even if served alongside a lunch or dinner program.

Director-level (or higher) business executives may support modest out-of-office meals that are not associated with a Speaker Program. Such meals should be incidental to a meaningful business discussion and adhere to the meal criteria outlined earlier in this section. Please reach out to the Compliance Department with any questions about appropriate attendees or agenda items.

The modesty of an out-of-office meal with an HCP should be evaluated based on local standards. For example, in major metropolitan areas, per-person limits should not exceed the following amounts:

Please note that these limits include all incidental costs associated with the meal, such as tax, tip, delivery fees, and any venue minimums. If a venue’s minimum requirement causes the per-person to cost to exceed Bausch + Lomb limits, you must thoroughly document your efforts to plan and execute the event, including the rationale for selecting a venue with a minimum requirement, and comply with all expense reporting procedures.

Alcohol may be provided during out-of-office meals only when permitted by local laws or regulations, never during business hours, and in modest amounts (e.g., no more than three drinks per attendee). Alcohol must never be excessive or the primary focus of the meal (such as at a happy hour), nor should it interfere with the exchange of scientific or educational information. The selection of alcoholic beverages should be modest and exclude top-shelf or premium spirits.

Bausch + Lomb colleagues are expected to exercise good judgment, professionalism, and program leadership when choosing to consume alcohol.

Bausch + Lomb should not directly sponsor or host meals at Continuing Medical Education (CME) programs. Sales colleagues must ensure that any meals they provide are not associated with CME events.

For the following cities, the meal limit at a restaurant for out-of-office meals and speaker programs is: $55 for breakfast, $100 for lunch and $150 for dinner per person, including food, beverages, tax and gratuity, due to the high cost of living in those cities: (1) San Francisco, C.A.; (2) Los Angeles, C.A.; (3) Washington, D.C.; (4) Chicago, I.L.; (5) Boston, M.A.; (6) New York City, N.Y.; (7) Miami, F.L.; (8) Atlanta, G.A.; (9) Las Vegas, N.V.; (10) Philadelphia, P.A.; (11) San Diego, C.A.; (12) Phoenix/Scottsdale AZ; (13) Fort Lauderdale FL.; (14) Orlando FL; (15) Seattle WA; (16) Aspen CO; (17) Denver CO; (18) Austin TX; (19) all of Hawaii; and (20) all of Alaska.

For additional guidance on specific interactions with healthcare professionals, please refer to Bausch + Lomb’s Interaction Guidelines applicable to the relevant Business Unit or product sales team.