Speaker Training

Promotional Speaker Programs

Bausch + Lomb organizes and supports Speaker Programs to promote its products and to educate healthcare professionals (HCPs) about the benefits, risks, and appropriate use of our products and related disease states. These programs aim to enhance awareness of Bausch + Lomb products, contributing to a more knowledgeable medical community and ultimately improving patient care. This policy does not apply to Continuing Medical Education (CME) or other independent educational programs that are not controlled by Bausch + Lomb. It also excludes service agreements with HCPs 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 designed solely to communicate scientific and clinical information about
Bausch + Lomb products and related disease states to healthcare professionals (HCPs). These programs facilitate peer-to-peer education, allowing for valuable exchanges of information regarding treatment options. The primary objective is to recruit appropriate attendees and deliver effective, educational Speaker Programs in accordance with
Bausch + Lomb policies.

Speaker Bureau Management

Speaker Programs are designed solely to communicate scientific and clinical information about
Bausch + Lomb products and related disease states to healthcare professionals (HCPs). These programs facilitate peer-to-peer education, allowing for valuable exchanges of information regarding treatment options. The primary objective is to recruit appropriate attendees and deliver effective, educational Speaker Programs in accordance with
Bausch + Lomb policies.

Speaker Selection

Speaker nominations and retention decisions are made strictly based on predefined, objective criteria. These are determined through combined research efforts, including internal Bausch + Lomb and independent third-party market studies, input from medical colleagues, and feedback from the field.

Speakers are evaluated on qualifications such as medical specialty, research background, publications, academic credentials, expertise, and reputation, using a formal and objective scoring system that ranks HCPs based on their professional and clinical experience.

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

Build relationships with the HCP,
Gain or enhance access to the HCP,
Reward past prescribing or encourage future prescribing,
Influence the HCP’s participation in other promotional activities, or
Secure benefits from any entity affiliated with the HCP.

Speaker nominations and retention decisions are made strictly based on predefined, objective criteria. These are determined through combined research efforts, including internal Bausch + Lomb and independent third-party market studies, input from medical colleagues, and feedback from the field.

Speakers are evaluated on qualifications such as medical specialty, research background, publications, academic credentials, expertise, and reputation, using a formal and objective scoring system that ranks HCPs based on their professional and clinical experience.

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

Build relationships with the HCP,
Gain or enhance access to the HCP,
Reward past prescribing or encourage future prescribing,
Influence the HCP’s participation in other promotional activities, or
Secure benefits from any entity affiliated with the HCP.

Written Speaker Agreement

All speakers must have a formal speaker agreement with Bausch + Lomb. Contract templates require Legal approval and should undergo review every 12–18 months as part of a renewal process. No speaker is authorized to present or receive payment without completing required training, passing screening against federal debarment lists, and having a fully executed agreement in place.

Written Speaker Agreement

All speakers must have a formal speaker agreement with Bausch + Lomb. Contract templates require Legal approval and should undergo review every 12–18 months as part of a renewal process. No speaker is authorized to present or receive payment without completing required training, passing screening against federal debarment lists, and having a fully executed agreement in place.

Speaker Training

Speaker Training is intended solely for preparing healthcare professionals to deliver accurate and appropriate information during promotional Speaker Programs. Training must not be used to influence speakers beyond this purpose. Materials presented should exclude prospective data and any Off-Label content.

Every speaker must complete training, including instruction on laws and regulations governing promotional activities.

For in-person training, venues must be suitable for effective communication and medical information education. If conducted virtually, training sessions should incorporate periodic participant check-ins to ensure comprehension and engagement throughout the program.

Speaker Training

Speaker Training is intended solely for preparing healthcare professionals to deliver accurate and appropriate information during promotional Speaker Programs. Training must not be used to influence speakers beyond this purpose. Materials presented should exclude prospective data and any Off-Label content.

Every speaker must complete training, including instruction on laws and regulations governing promotional activities.

For in-person training, venues must be suitable for effective communication and medical information education. If conducted virtually, training sessions should incorporate periodic participant check-ins to ensure comprehension and engagement throughout the program.

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 of sales management at training meetings should be carefully controlled, with the number of
Bausch + Lomb attendees limited to what is appropriate for the size of the audience being trained.

Program Materials

Like all Bausch + Lomb Promotional Materials, Speaker Programs must present a fair balance of risks and benefits. Relevant safety information—including warnings, precautions, side effects, and other important details about Bausch + Lomb products—must be disclosed or discussed according to the approved corporate presentation.

Multi-product promotional Speaker Programs are acceptable for promoting more than one product. For these programs, slides and materials related to each product must be adjusted to collectively fit within the allotted program time. Multi-product programs require corporate approval and may only use materials approved specifically for such purposes.

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

Program Materials

Like all Bausch + Lomb Promotional Materials, Speaker Programs must present a fair balance of risks and benefits. Relevant safety information—including warnings, precautions, side effects, and other important details about Bausch + Lomb products—must be disclosed or discussed according to the approved corporate presentation.

Multi-product promotional Speaker Programs are acceptable for promoting more than one product. For these programs, slides and materials related to each product must be adjusted to collectively fit within the allotted program time. Multi-product programs require corporate approval and may only use materials approved specifically for such purposes.

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

Fair Market Value Speaker and Trainer Payments

Speakers and trainers may only be compensated at Fair Market Value (FMV) for their services. FMV is determined by the individual’s expertise, experience, and time commitment. For guidance on payment caps, consult Marketing Operations or Compliance.

There must be no discussion or suggestion of a “quid pro quo” between speakers/trainers and
Bausch + Lomb, meaning colleagues may not imply or request prescriptions or product use in exchange for participation in speaker training or engagements.

No payment should be made unless the speaker has completed required training, been screened against federal debarment lists, and has a fully executed speaker agreement. These payments may also be subject to state and federal transparency disclosures.

Fair Market Value Speaker and Trainer Payments

Speakers and trainers may only be compensated at Fair Market Value (FMV) for their services. FMV is determined by the individual’s expertise, experience, and time commitment. For guidance on payment caps, consult Marketing Operations or Compliance.

There must be no discussion or suggestion of a “quid pro quo” between speakers/trainers and
Bausch + Lomb, meaning colleagues may not imply or request prescriptions or product use in exchange for participation in speaker training or engagements.

No payment should be made unless the speaker has completed required training, been screened against federal debarment lists, and has a fully executed speaker agreement. These payments may also be subject to state and federal transparency disclosures.

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 usage are removed from the active Speaker Bureau. A speaker’s daily maximum number of programs is three.

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 usage are removed from the active Speaker Bureau. A speaker’s daily maximum number of programs is three.

Lifecycle Management

Several factors influence the optimal number of programs, including new indications, sales force expansion, strategic shifts, budget changes, or a broader audience. Typically, the number of programs decreases after product launch, except when new indications or clinical data arise. Any increase in speaker usage requires business justification.

Lifecycle Management

Several factors influence the optimal number of programs, including new indications, sales force expansion, strategic shifts, budget changes, or a broader audience. Typically, the number of programs decreases after product launch, except when new indications or clinical data arise. Any increase in speaker usage requires business justification.

Non-U.S. Program Planning and Participation

For programs involving international speakers or attendees or held outside the U.S., additional regulations such as the Foreign Corrupt Practices Act (FCPA), U.K. Bribery Act, and other local laws apply. Organizers should consult supervisors or Bausch + Lomb’s Compliance Department for guidance on permissible activities. Review applicable laws to determine if any attendees or speakers qualify as foreign Government Officials or their agents.

Non-U.S. Program Planning and Participation

For programs involving international speakers or attendees or held outside the U.S., additional regulations such as the Foreign Corrupt Practices Act (FCPA), U.K. Bribery Act, and other local laws apply. Organizers should consult supervisors or Bausch + Lomb’s Compliance Department for guidance on permissible activities. Review applicable laws to determine if any attendees or speakers qualify as foreign Government Officials or their agents.

Conducting and Attending Promotional Speaker Programs

Speaker Programs should provide valuable educational content to attendees benefiting from this information in patient care. Programs must be planned and executed to comply with company policies and all relevant laws and industry standards.

Sales colleagues must discuss the business rationale and any challenges with managers during program planning to ensure resources are well used and the program benefits attendees. Manager approval is required before the event.

Conducting and Attending Promotional Speaker Programs

Speaker Programs should provide valuable educational content to attendees benefiting from this information in patient care. Programs must be planned and executed to comply with company policies and all relevant laws and industry standards.

Sales colleagues must discuss the business rationale and any challenges with managers during program planning to ensure resources are well used and the program benefits attendees. Manager approval is required before the event.

Program Conduct and Content

Bausch + Lomb is responsible for the conduct and content of all Speaker Programs, including statements made by speakers, even personal opinions. Speakers must comply with FDA regulations regarding product promotion.

All topics and materials must receive prior corporate approval through promotional review and must be used exactly as approved without alteration. Presentations must fairly balance risks and benefits, disclosing relevant safety information. Programs must begin with clear disclosure that Bausch + Lomb is the sponsor.

Off-Label Information may only be shared by speakers in direct response to unsolicited questions. If an unsolicited Off-Label question arises, the speaker should acknowledge its nature, respond briefly based on clinical experience, and steer the discussion back to approved uses. For detailed information requests, attendees should be referred to Medical Information Services.

If a speaker proactively shares Off-Label information without proper context, Bausch + Lomb colleagues must clarify this to the audience, remind the speaker of company policies afterward, and document the incident per company protocol.

Sales colleagues should report any potential policy violations at Speaker Programs to their managers or the Compliance Department.

Program Conduct and Content

Bausch + Lomb is responsible for the conduct and content of all Speaker Programs, including statements made by speakers, even personal opinions. Speakers must comply with FDA regulations regarding product promotion.

All topics and materials must receive prior corporate approval through promotional review and must be used exactly as approved without alteration. Presentations must fairly balance risks and benefits, disclosing relevant safety information. Programs must begin with clear disclosure that Bausch + Lomb is the sponsor.

Off-Label Information may only be shared by speakers in direct response to unsolicited questions. If an unsolicited Off-Label question arises, the speaker should acknowledge its nature, respond briefly based on clinical experience, and steer the discussion back to approved uses. For detailed information requests, attendees should be referred to Medical Information Services.

If a speaker proactively shares Off-Label information without proper context, Bausch + Lomb colleagues must clarify this to the audience, remind the speaker of company policies afterward, and document the incident per company protocol.

Sales colleagues should report any potential policy violations at Speaker Programs to their managers or the Compliance Department.

Attendee Requirements

In-Office or Healthcare Institution (HCI) Programs: Require at least two RSVPs from prescribers, dispensers, or injectors, unless intended for other HCP types like technicians or managers.
Out-of-Office or HCI Programs: Require at least four RSVPs, three of whom must be prescribers, dispensers, or injectors unless designed otherwise. Without minimum RSVPs, the program should be canceled.

Out-of-office attendees must:

Qualify independently as HCPs within the approved target audience.
Benefit from the educational content.
Practice in a specialty aligned with the product’s approved indications.
Be able to apply the education in patient care.

Sales colleagues must verify attendee specialties are consistent with product indications before programs. For patient programs, approved attendees include patients and caregivers.

Speakers typically may not attend programs for products they currently represent or conduct programs primarily attended by their own practice’s staff (technical trainings excluded). Out-of-office program attendees should come from multiple practices; most attendees should not be from the same practice.

Attendee Requirements

In-Office or Healthcare Institution (HCI) Programs: Require at least two RSVPs from prescribers, dispensers, or injectors, unless intended for other HCP types like technicians or managers.
Out-of-Office or HCI Programs: Require at least four RSVPs, three of whom must be prescribers, dispensers, or injectors unless designed otherwise. Without minimum RSVPs, the program should be canceled.

Out-of-office attendees must:

Qualify independently as HCPs within the approved target audience.
Benefit from the educational content.
Practice in a specialty aligned with the product’s approved indications.
Be able to apply the education in patient care.

Sales colleagues must verify attendee specialties are consistent with product indications before programs. For patient programs, approved attendees include patients and caregivers.

Speakers typically may not attend programs for products they currently represent or conduct programs primarily attended by their own practice’s staff (technical trainings excluded). Out-of-office program attendees should come from multiple practices; most attendees should not be from the same practice.

Speaker Program Attendance Limits

Additionally, the audience for an out-of-office Speaker Program should consist of HCPs from multiple practices (the majority of attendees may not be co-workers or staff from the same practice). HCPs are limited in the number of Speaker Programs they may attend.

Out-of-Office: HCPs may attend no more than three programs per calendar year per product and indication.
In-Office: Attendance should be occasional and tied to educational needs.

Attendees at multi-product programs must be qualified for all products presented.

Speaker Program Attendance Limits

Additionally, the audience for an out-of-office Speaker Program should consist of HCPs from multiple practices (the majority of attendees may not be co-workers or staff from the same practice). HCPs are limited in the number of Speaker Programs they may attend.

Out-of-Office: HCPs may attend no more than three programs per calendar year per product and indication.
In-Office: Attendance should be occasional and tied to educational needs.

Attendees at multi-product programs must be qualified for all products presented.

Use of Third-Party Vendors

Bausch + Lomb is responsible for all Speaker Programs that are arranged by Third Party vendors on our behalf. Any contract with a Third Party should specify that Bausch + Lomb’s Sponsorship of the event will be clearly disclosed and that the program will comply with all
Bausch + Lomb policies.

Transparency

Sales colleagues should accurately and completely capture and record any and all Transfers of Value (ToV) to an HCP as part of a Speaker Program. Any ToV to an HCP should be appropriately reported and in compliance with state and federal disclosure laws.

Reporting of Certification

Sales colleagues should complete a post program or event form within two (2) business days of a program. The post program or event form is required to show proof of service that the HCP speaking on
Bausch + Lomb’s behalf conducted the Speaker Program in accordance with their training and
Bausch + Lomb’s policies and procedures. Speakers will not receive payment until the post program or event form is completed.