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Professional Education Programs

Bausch + Lomb is committed to providing product instruction, education, and training on the safe and effective use of its products to healthcare professionals and Bausch + Lomb colleagues. These training and educational sessions are designed and delivered to benefit patients and enhance medical practice. Product training and education equip healthcare professionals with the necessary guidance to use Bausch + Lomb products safely and effectively. These sessions may take place in group settings or through individualized one-on-one training. Bausch + Lomb's professional education programs include:

  • Promotional Speaker Programs
  • Product & Technique Training
  • Proctorships
  • Preceptorships
  • Mentorships

Quick Tips:

  • Training and educational sessions are intended to instruct HCPs in a manner consistent with on-label product use.
  • All program presentations should be approved through Bausch + Lomb’s approved systems and processes.
  • Bausch + Lomb is responsible for the conduct and content of Training Programs. This includes proactive statements made by speakers that are inconsistent with the approved training, even if the speaker is discussing his/her own professional experiences and opinions.
  • The venue for the training and education should be conducive to the effective transmission of knowledge.
  • Preceptorships and Proctorships are focused on clinical, disease and treatment issues and are not designed to learn or evaluate the HCP’s business or billing practices.

In every professional education program, Bausch + Lomb colleagues are responsible for delivering the education in line with Bausch + Lomb’s Principles of Integrity and the policies outlined in this Guide, including:

Invitations

Representatives may only use corporately approved invitations provided by Bausch + Lomb or its authorized vendors. The design and layout of the invitation must highlight the educational presentation rather than the venue, food, or setting. No additions, changes, or modifications may be made to approved invitations without corporate approval, as this would render the invitations unapproved “homemade” materials. Photocopying invitations is prohibited. Invitations must clearly state that Bausch + Lomb is the sponsor of the program.

Invitations may be sent electronically in non-editable formats. Prior to an event, attendees may be required to RSVP directly through a centrally managed electronic system handled by a third-party vendor (unless the event is explicitly exempt). Additional attendees who meet the criteria may attend the program. All attendees must be tracked according to Bausch + Lomb’s requirements.

RSVPs

The centralized RSVP system is designed to reduce low- or no-attendance events and to prevent paying speakers for canceled or one-on-one programs. Attendees are generally required to RSVP through a centrally managed electronic system. Some programs—such as one-to-one remote peer sessions, technical training, and non-HCP directed events—may be exempt. Please consult your manager or Compliance for more details.

Attendees

All professional education programs must have a Bausch + Lomb sales colleague or trained personnel (from Bausch + Lomb or a third party) present to support the speaker and ensure compliance with company policies, regardless of the venue. Attendance must be documented using Bausch + Lomb-provided electronic or paper sign-in systems, with electronic signatures preferred. Paper sign-in sheets may only be used when electronic options aren’t available. Spouses, partners, and immediate family members of speakers or trainers may not attend programs led by them, even if they qualify independently as attendees. Other guests may attend only if they are healthcare professionals with a legitimate interest in the educational topic. Guests must meet attendee criteria regardless of who pays for their food. Attendees may not bring guests unless the guests qualify as appropriate attendees. Those not part of the approved audience may not attend any portion of the event.

Cancellations

A minimum of two prescribers, dispensers, or injectors must be present for a program to proceed, except when the program is designed for a single HCP or other specified attendee types (e.g., technicians). If fewer than the minimum RSVP attendees arrive, the program may continue as a courtesy. If a meal was ordered, the sales colleague can proceed with the event as a lunch-and-learn and must document the educational presentation and attendees. If no appropriate attendees are present, the event must be canceled. Sales colleagues cannot have a meal with the speaker or trainer or pay for their meal.
Sales colleagues and Third-Party vendors are responsible for managing attendance to minimize cancellations. If Bausch + Lomb cancels a program, the speaker will be paid in full if cancellation occurs within the timeframe specified in their agreement. Speakers who cancel will not be paid.

Business Meals at Professional Education Programs

Bausch + Lomb may offer modest meals and alcohol during these programs, if they adhere to the Business Meals section of this Guide. Entertainment or recreational activities are not permitted in conjunction with these programs.
Some states have laws that restrict or prohibit providing meals to healthcare professionals, state government employees, or members of State Formulary Committees. Colleagues working in states with such regulations must follow the applicable state laws and any instructions from their manager. For further details, please refer to the Summary of Healthcare Laws guidance.

Travel and Expense Reimbursement

Under certain circumstances, Bausch + Lomb may reimburse reasonable expenses related to these programs, including travel, lodging, meals, and other business-related costs (such as parking and taxi fares), provided that the expenses are properly documented and comply with Bausch + Lomb’s expense submission policies. Personal expenses, such as gift shop purchases, will not be reimbursed, nor will any costs have incurred by an HCP’s spouse or guest, as they are not eligible attendees.

These expenses may be subject to disclosure under state and federal transparency regulations. Therefore, accurate and thorough documentation is essential to ensure Bausch + Lomb’s compliance with all applicable disclosure requirements.

Promotional Speaker Programs

Bausch + Lomb supports and organizes Speaker Programs to promote its products and to educate healthcare professionals about the benefits, risks, and proper use of our products and related disease states. These programs aim to raise awareness of Bausch + Lomb products, leading to a better-informed medical community and, ultimately, improved patient care. This policy does not apply to Continuing Medical Education (CME) or other independent educational programs that Bausch + Lomb does not control. It also does not apply to service agreements with healthcare professionals who provide non-promotional consulting services or training to Bausch + Lomb colleagues.

All topics and materials used in any Speaker Program should receive corporate approval in advance through the promotional review process. Bausch + Lomb representatives are permitted to distribute corporate-approved managed-care related items, package inserts and Bausch + Lomb business cards. Speakers must only use corporate approved materials at Speaker Programs. Approved slide decks may not be altered unless pre- approved through Bausch + Lomb’s promotional review process.

Speaker Bureau Management

Speaker Programs are conducted solely to communicate scientific and clinical information about Bausch + Lomb products and related disease states to healthcare professionals (HCPs). These programs foster peer-to-peer education, enabling the exchange of valuable insights on treatment options. The primary goal is to recruit appropriate attendees and deliver effective, educational Speaker Programs in compliance with Bausch + Lomb policy.

Speaker Selection

Speaker nominations and retention are based exclusively on predefined, objective criteria identified through a combination of internal Bausch + Lomb research, independent third-party market studies, medical colleague input, and field feedback.

Speaker qualifications—including medical specialty, research experience, publications, academic credentials, expertise, and reputation—are assessed using a formal, objective scoring system that ranks HCPs according to their professional qualifications and clinical experience.

Speaking engagements must never be offered as inducements or rewards for prescribing or recommending Bausch + Lomb products. Therefore, sales colleagues are prohibited from nominating or engaging speakers to:

  • Build a relationship with the HCP.
  • Gain or enhance access to the HCP.
  • Reward previous prescribing or encourage future prescribing.
  • Encourage attendance at other promotional events.
  • Obtain benefits from entities affiliated with the HCP, including government bodies.

 

Written Speaker Agreement

All speakers must be engaged through a formal speaker agreement with Bausch + Lomb. Contract templates require Legal approval and must undergo periodic review and renewal every 12 to 18 months. No speaker is permitted to present or be compensated without completing the required training, passing federal debarment screenings, and having a fully executed speaker agreement in place.

Speaker Training

Speaker training must focus exclusively on preparing healthcare professionals to deliver appropriate information during promotional Speaker Programs. These training sessions should not be used to influence the speakers being trained. Content presented during speaker training must exclude prospective data and Off-Label information.

All speakers are required to complete training that covers relevant laws and regulations related to promotional activities.

If held in person, Speaker Training Meetings should take place in venues suitable for effective communication and medical education. For online trainings, periodic check-ins with attendees should be included to ensure understanding and engagement with the material.

Sales colleagues cannot organize a program with a speaker who appears on their call panel or call list more than six (6) times per calendar year, per product indication, inclusive of in-office and out-of-office programs.

Attendance at training meetings by sales management should be carefully controlled, limiting the number of Bausch + Lomb attendees to an appropriate level based on the size of the audience being trained.

Program Materials


As with all Bausch + Lomb Promotional Materials, Speaker Programs must present a balanced view of risks and benefits. Relevant safety information, warnings, precautions, side effects, and other significant details about Bausch + Lomb products must be disclosed or discussed following the corporate-approved presentation.

Multi-product Speaker Programs are suitable for promoting multiple products simultaneously. For these programs, slides and materials for each product should be adjusted to fit within the overall time allotted. Multi-product Speaker Programs require corporate approval and must use only materials approved for such presentations.

All other Speaker Program materials must undergo pre-approval through Bausch + Lomb’s promotional review process.

Fair Market Value Speaker and Trainer Payments


Speakers and trainers may only be compensated at rates consistent with Fair Market Value (FMV), which is based on their expertise, experience, and time commitment. For guidance on Speaker Program payment limits, consult Marketing Operations or Compliance.

There must be no discussion or implication of any “quid pro quo” arrangement for participating in
Bausch + Lomb’s Speaker Bureau. Sales colleagues may not, directly or indirectly, request prescriptions or product use in exchange for speaker participation.

Speakers must complete required training, clear federal debarment screenings, and have a fully executed speaker agreement before presenting or receiving payment. Payments may be subject to disclosure under state and federal transparency laws.

Utilization of Speakers in the Bureau

Speakers are generally expected to conduct at least two Speaker Programs annually. Those who do not meet this minimum will be removed from the active Speaker Bureau. No speaker may conduct more than three programs in one day.

Lifecycle Management

Several factors influence the appropriate number of programs, including indication expansions, sales force growth, strategic shifts, budget changes, or audience size increases. Typically, the number of Speaker Programs should decrease each year after product launch. Mature products generally require fewer programs unless new indications, line extensions, or additional data necessitate more. Any increases in Speaker Bureau size or program volume require business justification.

Non-U.S. Program Planning and Participation

Speaker Programs involving speakers or attendees outside the United States, or held internationally, must consider additional regulations such as the Foreign Corrupt Practices Act, U.K. Bribery Act, and local laws. Organizers should consult supervisors or Compliance for guidance on permissible activities and review whether any participants might be classified as foreign Government Officials or their agents.

Conducting and Attending Promotional Speaker Programs

Speaker Programs should provide valuable educational content that benefits healthcare professionals in treating patients. Planning and execution must comply with Bausch + Lomb policies, laws, regulations, and industry standards. Sales colleagues should discuss program objectives and challenges with their managers during planning to ensure appropriate resource use and program value, securing manager approval before implementation.

Program Conduct and Content

Bausch + Lomb oversees the conduct and content of Speaker Programs, including speaker statements. Speakers must comply with FDA product promotion regulations. All topics and materials require prior corporate approval and must be presented without alteration. Programs must maintain fair balance, fully disclosing risks, side effects, and other material product information. Sponsorship by Bausch + Lomb should be clearly disclosed at the start of each program.
Off-Label Information can only be shared by HCP speakers in response to specific unsolicited questions. Speakers should acknowledge when a question involves Off-Label use, briefly answer based on clinical experience, then steer back to approved uses. For detailed inquiries, attendees should be referred to Medical Information Services or provided with a medical request form.
If a speaker fails to clarify Off-Label content or presents it proactively, Bausch + Lomb colleagues must promptly identify the Off-Label nature, remind the speaker of guidelines, and document the incident through approved channels. Any suspected policy violations should be reported to managers or Compliance.

Attendees

For in-office or healthcare institution programs, a minimum of two RSVPs from prescribers, dispensers, or injectors is required unless the program targets different HCP types. Out-of-office programs require at least four RSVPs, with three from prescribers, dispensers, or injectors, unless otherwise specified. If minimum attendance isn’t met, programs should be canceled.

All out-of-office attendees must:

  • Independently qualify as HCPs within the approved target audience.
  • Benefit from the educational content.
  • Practice in specialties aligned with the product's approved indications.
  • Be capable of applying the education to patient treatment.

Sales colleagues must verify attendee specialties align with product indications before the program. For patient-focused programs, approved attendees are patients and caregivers. Speakers may not attend programs for products they currently represent and cannot conduct programs where most attendees are their co-workers or practice staff (except for technical training). Out-of-office program audiences should include HCPs from multiple practices, limiting the number of colleagues from the same practice. Attendance limits for HCPs are:

  • Out-of-office: No more than three programs per calendar year, per product and indication.
  • In-office: Attendance should be occasional and based on educational need.

Attendees of multi-product programs should qualify for all featured products.

Use of Third-Party Vendors

Bausch + Lomb is responsible for all Third Party-arranged Speaker Programs. Contracts must state that Bausch + Lomb’s Sponsorship is clearly disclosed and that programs comply with all company policies.

Transparency

Sales colleagues must accurately record all Transfers of Value (ToV) to HCPs during Speaker Programs and report them in compliance with state and federal laws.

Reporting of Certification

Sales colleagues must complete a post-program form within two business days, confirming the Speaker Program was conducted by the trained HCP in accordance with Bausch + Lomb policies. Speakers will not receive payment until this form is submitted.

Product Education

Bausch + Lomb delivers product instruction, education, and training focused on the safe and effective use of its products to ensure proper use and patient safety at all times. Training and education must never be used as an inducement or reward for prescribing or purchasing Bausch + Lomb products.

All product training sessions are designed to educate healthcare professionals in a manner consistent with FDA-approved product labeling and other applicable product requirements. All training materials must receive corporate approval in accordance with relevant policies. Healthcare professional educational programs may be conducted in centralized locations that are conducive to learning.

Participants must qualify within the approved target audience for each product covered in the training. They should benefit from the educational content, practice in specialties aligned with the approved product indications, and be capable of applying the information to patient treatment.

Proctorships

A Proctorship involves an objective assessment and training of a healthcare professional’s (HCP’s) clinical skills by a peer HCP, known as the Proctor/Trainer, who is compensated by Bausch + Lomb for providing this service. During the Proctorship, the Trainer serves as both an observer and instructor, evaluating the technical and cognitive abilities of the Trainee at the Trainee’s location.

  • Proctors/Trainers must not be directly involved in patient care or establish an HCP-patient relationship with the patient being treated.
  • Proctors/Trainers are prohibited from accepting fees from patients.

The specialties of both Trainers and Trainees should be relevant to the on-label uses of Bausch + Lomb products and align with medically or clinically appropriate therapeutic areas for those specialties.

Preceptorships

Preceptorships offer healthcare professionals (HCPs) a chance to learn from their peers about current medical practices and treatment protocols, enhancing their understanding of clinical and disease-related issues. During a Preceptorship, the Trainer serves as an instructor, assessing the technical and cognitive skills of another HCP at the Trainer’s location. Prior approval from the sales colleague’s Manager and Compliance is required before the colleague may engage with a prospective physician Trainee and Trainer.

All Proctorships and Preceptorships should abide by the following

  • Purpose/Design: These activities serve as a valuable peer review tool for healthcare professionals striving for proficiency and/or certification in treatments involving Bausch + Lomb products. They are strictly educational, focusing on therapeutic, clinical, and technical skill development. They must never be designed to assess or influence an HCP’s business or billing practices, promote products, affect prescribing behavior, or establish business relationships with the HCP.
  • Experience, Expertise, and Need: HCPs should be chosen based on their qualifications and expertise. Selection must not be used to reward prescribing habits or influence future prescriptions. These activities should be justified by a legitimate educational need and should not involve more HCP trainees than is necessary for the Trainee to achieve an acceptable level of proficiency.
  • Educational Value:  Documentation proving the educational benefit of the learning experience is required upon completion.
  • Written Contract:  Bausch + Lomb may engage HCPs for training related to education on its products, techniques, and related disease states only after a fully executed Consultant Agreement is finalized in accordance with the guidelines outlined in the Consultant Arrangement section of this Guide.
  • Payment Consistent with FMV:  Compensation for HCPs participating in a Preceptorship must align with Fair Market Value (FMV), considering the HCP’s qualifications, the services provided, and the time spent delivering those services.

Mentorships

Mentorships offer Bausch + Lomb colleagues the chance to learn from healthcare professionals about current medical practices, treatment protocols, and techniques to deepen their understanding of clinical and disease-related issues. These programs must never be designed to assess or evaluate an HCP’s business or billing practices, promote products, influence prescribing behaviors, or establish business relationships with the HCP. Since not all marketing teams provide funding for Mentorships, sales colleagues should first consult with their manager to confirm funding availability before starting the approval process. All Mentorships require prior approval from the sales colleague’s manager before engaging with a prospective physician and must include documentation demonstrating the educational value of the experience.

All Mentorships should abide by the following:

  • Purpose/Design: This activity is solely for educational purposes, focusing on the development of therapeutic, clinical, and technical skills. It must never be used to assess or evaluate an HCP’s business or billing practices, promote products, influence prescribing habits, or establish business relationships with the HCP.
  • Experience and Expertise: Healthcare professionals should be selected based on their qualifications and expertise. Selection must not be used to reward prescribing behaviors or influence future prescriptions.
  • Written Contract:  Bausch + Lomb may engage a Mentor to provide education on its products and related disease states only after a fully executed Mentorship Agreement is finalized.
  • Donations Aligned with Policy:  HCPs do not receive compensation for participating in a Mentorship. Instead, they may direct a monetary donation from Bausch + Lomb to a charity of their choice from a preapproved list provided by Bausch + Lomb. All donations must comply with Bausch + Lomb policies.
  • Patient Privacy:  Bausch + Lomb colleagues and contracted HCPs must respect and protect the privacy and confidentiality of all Protected Health Information (PHI) encountered during a Mentorship. A Bausch + Lomb colleague may not be present in an exam room unless the HCP has obtained a signed Patient Consent Form from the patient authorizing the colleague to observe. If a patient declines to sign, the sales colleague may continue the Mentorship but cannot be present in the treatment area (including exam rooms) during that patient’s visit or access that patient’s PHI. Patient Consent Forms are retained solely by the HCP and should not be returned to Bausch + Lomb or the sales colleagues at the end of the Mentorship.
  • Limited Number of Mentorships:
    • New hires may conduct up to two Mentorships per promoted product within their first 12 months of employment.
    • Tenured representatives may conduct:
    • One Mentorship per newly promoted product. A new product is defined as one that is entirely new to the colleague due to a portfolio change. If, because of a portfolio change, a tenured colleague is assigned a product they have not managed in the previous 24 months, that product will also be considered "new" allowing the colleague to conduct one Mentorship for it within the first 12 months after reassignment.
    • One Mentorship per newly approved and promoted product indication. Newly approved product indications do not include safety updates, dosing adjustments, or products launched with the same indication for which the employee received training during their first months of hire.
  • Silent Observer:
    Any Bausch + Lomb colleague involved in a Mentorship should act as a silent observer, allowing the healthcare professional to interact with the patient without interference or participation.
    Bausch + Lomb colleagues must not provide individual treatment advice or promote Bausch + Lomb products or services during the program.