Banner Image of Promotional Activity
Banner Image of Promotional Activity

Promotional Exhibits and Sponsorships

Bausch + Lomb utilizes promotional exhibits, displays, and Sponsorships at major scientific conventions as well as regional and local conferences to share product, disease state, and scientific information with healthcare professionals and consumers. Interactions at these commercial exhibits or promotional sponsorships are intended to inform customers about products and facilitate the exchange of educational and medical information. As such, all promotional activities should target audiences that include a substantial number of legitimate, practicing healthcare professionals.

This policy applies to all Bausch + Lomb Colleagues attending conferences within the United States. For conferences held outside the United States, you should consult your supervisor or Bausch + Lomb’s Compliance Department for guidance.

Quick Tips:

  • All materials displayed at commercial booths must be approved through the Bausch + Lomb approved promotional review process.
  • Display or Exhibit fees should be consistent with FMV for the promotional opportunity.
  • Commercial and Medical Affairs booths should be completely separate and distinct from one another.
  • Promotional Sponsorships should only support events and activities in which Bausch + Lomb can reasonably promote its products consistent with approved FDA labeling.
  • Promotional Sponsorships should not be provided to individual practices, individual/ private HCPs, private practice groups or clinics; or to any organization that is controlled by an individual/private HCP, private practice group or clinic.
  • The Promotional Sponsorship should be for an amount that is consistent with the FMV of the benefit that Bausch + Lomb receives in return.

Submission and Review Process

For major corporately managed conventions, no additional paperwork is needed as long as the event is handled by Marketing Operations. For all other promotional sponsorships, approval must be obtained by submitting a Promotional Exhibit and Sponsorship Request Form through Bausch + Lomb’s approved processes and systems.

Sales, marketing, managed markets colleagues, managers, and all approvers share the responsibility to ensure that:

  • The request is from a bona fide independent association or program vs. an individual HCP.
  • The proposed venue is appropriate for and conducive to the approved purpose of the promotional exhibit or Sponsorship.
  • The proposed budget is reasonable and commensurate with Fair Market Value.
  • The exhibit or Sponsorship request is based on the merits of the proposal, not on any business relationship between Bausch + Lomb and the recipient or any purchase of products by the recipient (or lack thereof).
  • The content of the program or convention presented is within approved product indications.
  • The majority of audience members practice within appropriate specialties.
  • W-9, Agenda and Letter of Request should be provided to validate all of the above.

Display Fees

Bausch + Lomb may pay display or exhibit fees to legitimate event organizers in accordance with Fair Market Value (FMV) for booth opportunities. Such fees should not be paid to healthcare professionals, pharmacies, physician groups, or individuals.

Displays

The three most common types of displays are commercial booths, medical affairs exhibit booths, and disease state booths:

  • Commercial Exhibits: Commercial booths are promotional in nature. All materials displayed or distributed from these booths must be on-label and approved through Bausch + Lomb’s approved processes and systems prior to the event. Bausch + Lomb colleagues should not discuss Off-Label uses of products with healthcare professionals (HCPs) visiting a commercial booth. If an HCP raises an Off-Label question, colleagues should refer them to Medical Affairs if onsite. If Medical Affairs is not present, colleagues should direct the HCP to Medical Information Services (MIS) by providing a copy of the Customer Relations and Medical Affairs business card or a “Request for Medical Information Form.”
  • Medical Affairs Exhibits: Sales and marketing colleagues, except those handling logistical support like the convention team, are not permitted to participate in planning or staffing Medical Affairs exhibits. These exhibits provide HCPs with clinical and scientific information free from promotional content and should be staffed exclusively by clinical or medical personnel.
  • Disease State Exhibits: These exhibits, typically found at medical congresses, offer HCPs relevant information about a specific disease state. They may be staffed by either sales and marketing colleagues or Medical Affairs personnel.
    • Questions about Bausch + Lomb products that align with approved labeling may be answered by the colleague present, following promotional policies and procedures.
    • If an HCP asks an Unsolicited Off-Label question, sales or marketing colleagues should refer them to the Medical Affairs exhibit. If Medical Affairs is not available at the conference, colleagues should direct the HCP to Medical Information, provide a Customer Relations and Medical Affairs business card, or submit a request via the electronic Medical Information Inquiry process (available to sales colleagues only).

Physical and Distinct Separation of Commercial and Medical

At conferences or conventions where Bausch + Lomb has both commercial and Medical Affairs exhibits, the two areas must be physically separated. They should be clearly distinguishable from one another, with distinct appearances that reflect their different promotional and educational purposes. In cases where it has been specifically approved through the appropriate Bausch + Lomb process, the Medical Affairs presence may be situated within the Commercial booth, but only if there is a clear separation between the two sections (e.g., a separate entrance).

HCP Meetings at Conferences

Occasionally, Bausch + Lomb may sponsor a meeting with healthcare professionals (HCPs) held concurrently and at the same location as a conference. In such instances, the Bausch + Lomb-sponsored meeting must be clearly distinct and separate from the conference, both in appearance and in practice. The meeting should also comply with all relevant Bausch + Lomb guidelines corresponding to the type of meeting being conducted, such as those for Advisory Panels, Promotional Speaker Programs, or Product Theaters.

Promotional Sponsorships

Bausch + Lomb may provide Sponsorships funds to a variety of trade, medical, professional, patient, scientific, and community organizations. Marketing Promotional Sponsorships involve offering financial support to an organization in exchange for something of value, such as promotional display space, an exhibit booth at a major national industry convention, or signage recognizing Bausch + Lomb at a specific sponsorship level.

It is important to note that Promotional Sponsorships are different from charitable contributions, research grants, and educational grants.

  • A charitable contribution is funding given to a nonprofit organization to support activities with a primary charitable purpose, such as a fundraising gala.
  • An educational grant is funding provided to support events primarily focused on educating participants or attendees.

External organizations often use terms like sponsorships, grants, charitable contributions, and donations interchangeably and inconsistently. However, the nature of an event is determined by Bausch + Lomb’s definitions based on the event’s specific characteristics—not by how a third party labels the funding request. Bausch + Lomb’s policies will govern how such requests are classified and managed.

Any Bausch + Lomb colleague requesting sponsorship funding must ensure that the request is for activities that Bausch + Lomb is authorized to support.

Requests for Support
Requests for Promotional Sponsorships must be submitted by the internal requester through the designated Bausch + Lomb system and include all necessary supporting documentation.

Fair Market Value
Bausch + Lomb may receive nominal benefits in return for providing financial support. The sponsorship amount should align with the Fair Market Value (FMV) of the commercial activity or benefit received by Bausch + Lomb.

Written Agreement
Bausch + Lomb colleagues must ensure that a written contract outlining the sponsorship is fully executed before any financial support is provided.

For charitable contributions or grants, Bausch + Lomb Colleagues should re-direct the external requesting organization to the appropriate contact information outlined in the Educational Grants, Research Grants and Alliance Advocacy Support section of this Guide.