Events and hospitality — the cap, the venue, the companion, the briefing.

The hospitality cap is the number everyone in Australian pharma knows and the one thing about events the Code no longer states. Edition 20 moved it — and most of the other operating detail — out of the Code and into the Tool Kit, leaving Section 4 as a set of principles that read as obvious until a Four Corners producer reads them back to you. This guide is Section 4 and the guidance around it, in the Code's words, organised the way an event is actually planned: what kind of event it is, who is speaking, what is served, where, who travels and how, who is being sponsored, what is on the stand, and what goes home in the bag. It is written for the people who book the rooms as much as for the people who approve them.

The principle over the section

Section 4 opens with one sentence: "Whether Company-initiated or sponsored, activities should be consistent with the Principles of the Code" § 4. Two of the ten Principles do most of the work. "All events, initiated or sponsored by Companies, are reasonable and appropriate with respect to hospitality, travel and accommodation, therefore upholding the integrity and reputation of the industry" § OP 9; and "nothing is offered or provided by a Company in a manner or with conditions that would have an inappropriate influence on the approval, recommendation, prescribing, and/or use of a product" § OP 5.

The hospitality clause adds the test the Committee applies: companies "will ensure that they act in a manner which upholds the integrity and reputation of the industry and does not compromise the independence of healthcare professionals", and "will also ensure activities and interactions with healthcare professionals can withstand public scrutiny" § 4.5. The Tool Kit calls it the pub test. Every specific rule below is an instance of it, and where a situation falls between the rules, it is the rule.

Two definitions to hold onto. "Hospitality means the provision of food and/or beverages" § Glossary — nothing else. "Entertainment means the provision of any diversion or amusement" § Glossary — and the Code forbids it outright.

Three kinds of event

The Code distinguishes events by who controls them, and the obligations follow the control.

Company-initiated. "Where the Company initiates and manages the agenda, duration of educational content, and speaker selection" § 4.1, three things are required. Objective evidence of educational value — "for example, an invitation or agenda" — "that clearly describes the purpose, content, meeting start and finish times and duration of educational sessions" § 4.1(a). An educational program "reviewed and approved through an internal Company process" § 4.1(b). And a speaker briefing, which has its own section below § 4.1(c).

Third-party. Companies may sponsor events "organised by a society, college, university or other healthcare professional organisation", including in-institution events — "journal clubs, grand rounds, multidisciplinary and in-service meetings held within the healthcare professional's workplace" § 4.2. The organiser "should independently determine the educational content, select the speakers and attendees" § 4.2(a); the company still weighs "the objective evidence of the educational value of the event, including the event location and program" before sponsoring § 4.2(b); the venue may be the third party's choice "as long as the venue has appropriate facilities for holding educational events" § 4.2(c); and the money goes "to the organisation arranging, conducting or responsible for the event, and not to an individual healthcare professional" § 4.2(d). Sponsorship is not control — the Tool Kit's Hospitality and Venues Guidance is clear that a sponsor still owes due diligence on the venue and the hospitality, and the Help Desk's answer on a specialty group meeting at a sports ground is that the venue can be sponsored if on its face it meets the criteria — appropriate facilities, no leisure activity on the day, no grandstand access — and passes the pub test besides.

Virtual. Video sales calls, remote detailing, virtual meetings and online conferences are all permitted, and the Principles apply regardless of the medium. The Tool Kit's Conducting Virtual Meetings Guidance adds the operating rules: access to anything carrying promotional claims restricted to verified healthcare professionals; unapproved products and indications not promoted, with scientific exchange under the Medical Director as the route for that content § 7; and a global online congress with a mixed audience not a place to promote a product unless attendees are from a market where it is registered.

The speaker briefing

The clause most often missing from the event file. "Companies should ensure that healthcare professionals speaking at Company-sponsored educational events or Congresses are aware of the obligation not to promote unapproved products or indications. This applies irrespective of whether the Company has provided the healthcare professional with a presentation or other material. Companies should be able to produce documentary evidence of this briefing and its content, which can be publicly disclosed if required" § 4.1(c).

Read the middle sentence twice. A speaker using their own slides is still the company's speaker for this purpose, and the company still needs the briefing on file — and the file has to be fit for the public. The exemption is narrow: the briefing obligation "does not apply to independent third-party educational events or Company-sponsored educational events where an independent scientific faculty has chosen the topics and speakers" § 4.1(c). A company that chose the speaker owes the briefing.

What the briefing says is the company's, but it needs to carry the obligation in terms the speaker can act on: the Australian Product Information for the product and the indications registered here; that content outside the Australian PI — a use approved elsewhere, a trial in a population the PI does not cover, a dose the PI does not carry — may not be promoted from the platform; that where the audience asks, the answer is a referral to Medical rather than a claim from the stage; and that the deck, if the company has seen it, has been reviewed against the PI. Off-label is wider than a disease name, and the off-label guide sets out the five tests a speaker's content is held to.

Hospitality — the cap, and what sits under it

"Companies may provide hospitality (food and beverages) if it is secondary to the purpose of an activity" § 4.5(b). It "must be moderate and reasonable as judged by local standards, which in Australia is stipulated by a capped maximum spend per person. This amount is outlined in the Code Tool Kit" § 4.5(c).

The figure, from the Hospitality and Venues Guidance (published November 2022, revised March 2025): AUD $140 per person per meal, excluding gratuities and GST, in effect since 3 November 2022 and reviewed annually. Cite the Tool Kit for it, not the Code, and expect it to change without a new edition.

The Guidance is more useful on what the cap is not. It is a maximum, not a target — reaching it "should be the exception, not the rule". A breakfast or a lunch should not approach it; the ceiling is for a substantial educational event, the learned-society dinner in a capital-city hotel, not a representative's lunch with four general practitioners. The per-head figure is judged on anticipated numbers — confirmed acceptances — so a run of no-shows that pushes the arithmetic over the cap is forgiven if the plan was inside it; the Guidance's defensive practice is an internal budget below the cap, say $120, to absorb the drop-offs. Alcohol is permitted, modest — beer and wine, not spirits or cocktails — counted within the cap, and a common internal rule is that its value must not exceed the food's.

Three settings the Guidance treats specifically.

The sales call. Modest hospitality at the professional's place of work is appropriate — coffee and morning tea, a simple lunch if the meeting spans it. Off-site only where justified. No alcohol at a sales call.

The virtual event. Meal delivery to a professional's workplace during the working day is acceptable, with a company staff member present in the room or on the call, or paired with a formal educational activity — a webinar, a journal club, grand rounds. The company carries the onus of showing the professional was present for the duration.

The home. Never. "Companies may not provide hospitality to a healthcare professional at their home or usual place of residence" § 4.5(d), and the Help Desk has said this holds for virtual events too: the original rationale for hospitality — a meal missed at work — does not apply at home.

Outside Australia, "any meal (food and beverages) provided in another country complies with the monetary limit set by the industry association in that country (where applicable). If there is no such limit in that country, any meal provided must be moderate and reasonable, following Australian principles" § 4.5(j).

The venue

"A facility should be selected for its appropriateness to enable the activity to be conducted and should not be chosen or utilised for the purpose of leisure, sporting or recreational activities" § 4.5(a). "Companies may not provide entertainment to healthcare professionals" § 4.5(e).

The Code stops there; the Tool Kit and the Help Desk fill in the judgement. A venue should be chosen because it can deliver the education — private, with the capacity and the audio-visual the program needs, out of the public's sight and hearing — and not because it is a drawcard. Renowned or extravagant venues are to be avoided; resort branding is a red flag; "leisure by association" — a venue trading on entertainment happening beside it — counts against it; a hatted restaurant is acceptable if the dining is not the point. No company-arranged recreation during a meeting, even if nobody paid for it. In a regional town where the only private room with a screen is at the RSL or the bowling club, that room is appropriate precisely because there is no alternative; in a city with options, a hotel or a restaurant with conference facilities is preferred.

One Help Desk note should change how the file is kept. Where a product meeting cannot be held in a private workplace setting, a non-private venue can be acceptable if it is out of earshot, the visual aids are out of eyesight, the venue is discreet and the hospitality modest — and the Code Committee has said companies should document the venue options considered and the rationale for the choice, to be produced if a complaint is lodged. The record of the venues you did not book is part of the defence of the one you did.

Trade displays raise a different venue question: "if the primary audience is broader than healthcare professionals, a Company should carefully consider whether the promotional trade display or the information to be made available from a trade display involves the promotion of products to the general public, which may contravene the Commonwealth Therapeutic Goods Act" § 4.3(d).

Travel, accommodation, and who comes

"Companies may provide travel only in direct association with educational event/s or to undertake a consulting service" § 4.5(g). Accommodation may be provided for a company or independent educational event or a consultancy, "provided it is reasonable and appropriate to the time and duration of the event or consultancy, and to the distance from where the healthcare professional usually resides" § 4.5(f).

The class of travel is written into the Code: for an international educational event "either economy or business class; domestic air travel and to New Zealand is by economy class only. The most direct route should be booked, without the allowance of more time at the destination than is reasonably justified to enable the healthcare professional to effectively participate in the event/s" § 4.5(h). The Help Desk allows a professional to stay on after a sponsored event for a legitimate co-located activity in their field, domestic or international, provided the company pays nothing further — no extra nights, no hospitality, no per diem — and the professional can evidence the activity.

Who comes is the clause that ends careers. "Companies should only support the attendance of the healthcare professional who are participating in the event or providing the service to the Company. It would be considered a gift or inducement if a Company was to provide hospitality, travel or accommodation to spouses, relatives, guests or companions of healthcare professionals and non-healthcare professional practice staff when they are accompanying a healthcare professional" § 4.5(i). The Help Desk's operating advice: do not invite companions and do not pay for additional rooms; if a professional chooses to share their room, the added cost is theirs, and the company is not required to police who stays. Practice staff are in the same position as companions — the interaction exists to inform the professional — with common sense for the receptionist who is incidentally at the lunch, and a hard line against any arrangement in which access to the practice is conditional on hospitality. The one allowance the Help Desk carves out is for a breastfeeding professional: an infant in the room, a support person travelling, an infant at the event are all appropriate, at the professional's cost, and a policy too rigid to allow them disadvantages the parent without serving the principle.

Sponsoring a professional to attend

Sponsorship "may be provided to enable a healthcare professional to attend an educational event, provided the meeting is directly related to the healthcare professional's area of expertise, qualifications, experience, and educational needs" § 4.4(a). The company must have "clear guidelines, which can be publicly disclosed if required" covering how it establishes the educational value of an event — "its location, program, and hospitality provided" — the appropriate reasons for support, "the review and approval process for providing support, demonstrating that the support is independent of sales considerations", and how each sponsorship is documented, "e.g. a written agreement with the healthcare professional" § 4.4(b).

Two lines the Code draws around it. Sponsorship is not payment: "a payment (including donations to charities or societies) must not be made to a healthcare professional as an incentive or in return for their attendance at an educational event or trade stand. Sponsorship to enable attendance at an educational event may be provided" § 5.1(c). And sponsorship is not a prize — the Help Desk's answer on guidelines is that awarding it through a competition trivialises the relationship and the Code does not support it.

Sponsorship is also a transfer of value, and it is published. Registration fees, travel and accommodation are reported against the individual professional whoever was invoiced § 14.1(d), while hospitality alone at an educational meeting is not reportable, though it must still comply with the rules above § 14.2(c). The amount paid to a meeting organiser for a trade display is reported as sponsorship § 4.3(a). The transparency reporting guide covers the schedule and the template; the Reporter produces the filing from the events ledger.

Trade displays and the congress exception

A company may display or supply information about "a product or an indication not approved for registration in Australia" at an international or Australasian congress held in Australia, "provided any material used clearly identifies that it refers to a product or indication not approved in Australia, and that the product or indication (as appropriate) is approved overseas" § 4.3(b). The product "must be approved for marketing in an overseas country targeted by the conference organisers"; a prominent, appropriately worded label satisfies the section; and the information "must be consistent with Product Information in the country where the product is registered", with that PI "available and distributed in accordance with the Code" § 4.3(c).

The Glossary sets the boundary of the exception. An "international congress means a congress held in Australia where a Society or College in an overseas country is actively organising and has joint control over the conference with an Australian Society or College" § Glossary. An Australian society's annual meeting with an international keynote is not one. And where non-professionals have registered to attend, the company "should make reasonable efforts to request the conference organisers to include a note in the conference program that staff at Company trade displays are precluded by law from giving information about specific products to non-healthcare professionals" § 4.3(e).

What may be handed out

Section 3 governs the bag. Companies "may provide medical literature, reprints and proceedings of educational events to healthcare professionals, but no part of a reprint or article should be specifically highlighted to draw the attention of the healthcare professional" § 3(a). They "do not offer items or gifts, which may inappropriately influence prescribing a product"; what is appropriate is "Company-branded items, of low monetary value, relevant to the conduct of the educational meeting", given "to HCPs attending the educational meeting", and "Company-branded educational material" § 3(b).

The Tool Kit's Gifts, Offers and Company Branded Items Guidance turns that into a list, and it is stricter than most affiliates' cupboards. Gifts for personal benefit are prohibited regardless of value — cash, cash equivalents, personal services, tickets, electronics, social-courtesy gifts. Promotional aids and brand-name reminders are out regardless of value and regardless of whether they carry the company's name: post-it notes, bags, binders, calendars, stationery, trinkets, coffee cups, water bottles, mouse pads, diaries, clinic supplies. Lanyards are no longer permitted as giveaways at all, even plain ones, since the IFPMA's 2021 change; the only acceptable form is a loan with active collection at the end. Tote bags only if relevant to the meeting and not retained; a USB only if it carries the meeting's material and is sized for it.

What remains: a textbook relevant to the professional's practice, of reasonable value and not handed over as a gift; reprints and proceedings; educational items that may carry the company's name but not a product's, unless the product name is essential to a patient's correct use; a pen and a notepad on the chairs for taking notes; single-use consumables at the meeting. The Guidance's test is context — the same pen on the chair is a note-taking aid, and in a goodie bag or on the booth table it is a gift. Company-run competitions may offer no prizes; a third party's congress passport with a prize of reasonable value may be joined if it supports the educational content. For a mixed or public audience, the Help Desk's line is that low-cost consumer-appropriate items may be acceptable, and stress balls and fluffy toys trivialise the industry.

The file

None of this is the Code's; the Code sets the standard and the Tool Kit the figures. But an event file that would survive a complaint or a Monitoring Committee request § 15.8 holds the same eight things every time, and a policy that names them saves a compliance team the reconstruction.

1. The invitation or agenda, with purpose, content, start and finish times and the duration of the educational sessions § 4.1(a) — or, for a sponsored event, the organiser's program and the assessment of its educational value § 4.2(b).
2. The internal approval of the program § 4.1(b).
3. The speaker briefing and evidence it was given, in a form that can be disclosed § 4.1(c).
4. The venue decision — the options considered and why this one — and the confirmation that it offers no leisure, sporting or recreational element and no entertainment § 4.5(a), § 4.5(e).
5. The hospitality budget per head on confirmed numbers, inside the Tool Kit cap, with alcohol counted; and, for a virtual event, the delivery address as a workplace § 4.5(c), § 4.5(d).
6. The attendee list — participants only, no companions, no practice staff supported § 4.5(i).
7. Travel and accommodation — direct route, correct class, nights matched to the program and the distance § 4.5(f), § 4.5(g), § 4.5(h).
8. The sponsorship decisions against the published guidelines, with the written agreements § 4.4(b) — and the lines they will become in the transparency report § 14.1(d).

The Tool Kit's Good Practice Guide on hospitality policies asks for one more thing of the policy itself: that it not simply repeat the Code's words. "Modest and reasonable" is the standard, not a budget; a policy that steps the limits out by meal and by context, addresses the sales call and the virtual event, and is reviewed every one to three years is the one that changes what gets booked.