Guide · Updated 29 August 2026 · 10 min read
The Code Tool Kit — a map of everything that isn't in the Code.
Edition 20 moved the operating detail out of the Medicines Australia Code of Conduct and into the Code Tool Kit — the hospitality cap, the complaints procedure, the templates, the guidance and the Help Desk's answers. This is the whole Tool Kit on one page: every document, the clause it serves, its date, which parts bind and which advise, and how to cite it so a citation survives the next revision.
Ask where the hospitality cap is written down and the answer, since March 2025, is "not in the Code". Edition 20 is a principles document; the numbers, the procedures, the templates and the worked answers moved to the Code Tool Kit, a set of pages on the Medicines Australia Code website that changes without an edition number. That makes the Tool Kit the document a compliance team actually opens most days, and also the one nobody has a complete list of. This is that list — every document on the Tool Kit as it stands, the Code clause each one serves, when it was last revised, and which of them bind rather than advise — with the citation habits that keep a reference from going stale.
What it is, in the Code's words
The Code introduces it in one sentence: "To enhance understanding and application of this Code, Medicines Australia has created Guidance and educational resources which are hosted in the Code Tool Kit. Both the Code and the Tool Kit are available from Medicines Australia's website" § Interpreting this Code. The Glossary defines it as "the current Code of Conduct Resource Code Tool Kit" § Glossary — and current is the word that matters. Where the Code says "the Tool Kit", it means whatever is there today.
The Tool Kit is not one kind of thing. It has three tiers, and the difference decides how a document is cited and how far it can be argued with.
Delegated — the Code sends you there for a rule. Five clauses hand an obligation to the Tool Kit outright. The hospitality limit: "a capped maximum spend per person. This amount is outlined in the Code Tool Kit" § 4.5(c). The complaints procedure: "detailed guidelines for lodging a complaint, responding to a complaint, and raising an appeal can be found in the Code Tool Kit" § 15. Intercompany dialogue: "Companies will follow the Intercompany Dialogue Standards, which are described in the Code Tool Kit" § 15.1(c), enforced by a fine of $100,000 § 15.6. Starter-pack law: "A summary of this information can be found in the Code Tool Kit" § 6.1(b). And patient organisations: "Companies should refer to the Working Together – A Guide to Relationships between Health Consumer Organisations and Pharmaceutical Companies" § 11(a). These documents carry the Code's own force; the Standards for Intercompany Dialogue are the clearest case, since not following them is itself a breach § 15.5.
Interpretive — guidance on what a section means. The Promotional Claims Guidance, the Balance Guidance, the Scientific Exchange FAQs and their siblings. They are Medicines Australia's reading of the Code, published to help companies apply it. A Code Committee is not bound by them, but a company that departs from them is arguing against the referee's published view.
Precedent-like — the Notes from the Help Desk. Numbered answers to recurring industry questions, many grounded in adjudicated complaints. Not binding, revised as the Code changes, and the closest thing the Australian system has to published practice.
The rest of this page walks the Tool Kit by its own pages.
Guidance
The main page, nineteen documents. The dates are Medicines Australia's; where a document has been revised, the latest revision is the one in force.
| Document | Serves | Published / revised | Tier |
|---|---|---|---|
| Overarching Principles (one-pager) | § OP 1–§ OP 10 | Part A of Edition 20, in effect 30 March 2025 | Reproduces the Code's text |
| Developing and Communicating Compliant Promotional Claims (the Promotional Claims Guidance) | § 1, § OP 8 | March 2025, revised February 2026 | Interpretive — the five tests of PI consistency; the hierarchy of evidence |
| Balance in Product-Related Materials | § 1.1 | January 2024, revised March 2025 | Interpretive |
| Prescribing Information in Product-Related Materials | § 2.1 | March 2025 — replaces "Using QR Codes or Hyperlinks" (2021) | Interpretive — the Min PI is optional; the access statement is not |
| Hospitality and Venues | § 4.5, § OP 9 | November 2022, revised March 2025 | Delegated — carries the per-person cap |
| Hospitality Policies — Good Practice Guide | § 4.5 | August 2022, revised June 2023 | Interpretive — what an internal policy should contain |
| Conducting Virtual Meetings | § 4, § OP 9 | August 2021, revised March 2025 | Interpretive |
| Gifts, Offers and Company Branded Items | § 3, § 5, § OP 5 | December 2021, revised June 2023 and March 2025 | Interpretive — the prohibited list; the context test |
| Good Practice Guide — Grants and Donations | § 5.2 | July 2025 | Interpretive |
| CEP — Company Representative Training Guidance | § 9 | CEP suite, 2025 | Interpretive |
| CEP Policies — Good Practice Guide | § 9 | CEP suite, 2025 | Interpretive |
| Scientific Exchange — Frequently Asked Questions | § 7 | March 2025 | Interpretive — who may deliver it; proactive vs reactive; whether the § 2.1 inclusions apply |
| Ethical and Compliant Use of Social Media | § 10.2, § 10.1 | April 2025 | Interpretive — the five-step framework |
| Patients and Their Representatives — Ethical Communication | § 11, § 12, § 13 | March 2024, revised 2025 | Interpretive |
| Sampling Regulations Summary Table | § 6.1(b) | May 2023, republished May 2025 for Edition 20 | Delegated — the state-by-state law on starter packs |
| Standards for Intercompany Dialogue | § 15.1(c), § 15.5 | Published 30 October 2024, in effect 30 March 2025 | Binding — a breach is a Code breach |
| Complaints Process for Industry (Guidelines for Industry-Generated Complaints) | § 15.1–§ 15.7 | February 2022, revised October 2025 | Delegated — what a complaint and a response must contain |
| Complaint Process for Non-Industry (Guidelines for Non-Industry Complainants) | § 15 | February 2022, revised March 2025 | Delegated |
| Code of Conduct Committees — Membership Selection Process | § 16 | November 2021, revised January 2025 | Procedural |
Three of these are covered clause by clause elsewhere on this site: the Promotional Claims Guidance and the Scientific Exchange FAQs in the off-label guide, the Standards and the complaints guidelines in the complaints guide, and the hospitality and gifts guidance in the events guide.
Transparency reporting resources
A page of its own, because § 14 is the part of the Code with the most paperwork. Eleven items: five documents and six templates.
| Item | Serves | Published / revised | What it is |
|---|---|---|---|
| Transparency Reporting — A Quick Guide | § 14 | April 2022, revised March 2025 | The three reporting arms, their dates and destinations |
| Fact Sheet for Healthcare Professionals: Transparency Reporting | § 14.1 | March 2025 | What is reported about them and why — the sheet to hand a professional who asks |
| Transparency Decision Tool | § 14.1–§ 14.3 | 2025 | A flowchart: is this reportable, and in which report |
| Transparency Reporting FAQs (v3) | § 14 | Revised March 2025, updated March 2026 | Twenty-seven edge cases |
| Collection Statement for Use in HCP Engagements | § 14.1(f) | Template (Word) | The pre-engagement notice that the value will be published |
| Healthcare Professional Verification Letter | § 14.1 | Template (Word) | The post-period letter giving the professional their lines to check |
| Medical Practice Activity Agreement | § 5 | Template (Word) | Documents a service arrangement with a practice |
| Verification Accompanying Report | § 14.1 | Template (Word), May 2026 | Confirms the report is complete when it is lodged |
| Payments and Transfers of Value to HCPs | § 14.1 | Template (Excel), Edition 20 | The Disclosure Australia report |
| Sponsorship of Third-Party Events, including Grants and Donations | § 14.2 | Template (Excel), March 2025 | The second report |
| Patient Organisation Support | § 14.3 | Template (Excel) | The third report |
The templates fix the vocabulary — the healthcare-professional types, the service types, the amount columns — and the vocabulary is the thing an affiliate's own systems never quite match. The transparency reporting guide works through the schedule and the columns; the Reporter produces the filing in the template's own terms.
Working Together
The Code's reference for patient-organisation relationships is "the Working Together – A Guide to Relationships between Health Consumer Organisations and Pharmaceutical Companies, published on the Medicines Australia website" § 11(a). On the Tool Kit the page is Working Together: Patients and Industry, and it carries seven fact sheets published in October 2025, written for the patient side of the relationship as much as the company's:
- Introduction to the Code
- What does the Code mean
- Financial support 101
- Patient attendance
- What can and can't be said
- Clinical trials
- Working together
They are the plain-language version of § 11, § 12 and § 13, and the right thing to send a patient organisation before the first conversation about support — since the Code requires a company to tell the organisation that any sponsorship "will be publicly disclosed" § 14.3(d).
Notes from the Help Desk
Sixty-three numbered notes, running from #4 to #107 with gaps where notes have been retired; most were first published between 2021 and 2023 and revised in March 2025 for Edition 20, and the newest are written to Edition 20 from the start. They fall into nine subjects:
- Promotional claims, balance and substantiation
- Events, hospitality, venues and gifts
- Scientific exchange, off-label and pipeline
- Patient organisations, patient stories and patient support programs
- Transparency reporting
- Communications — media, social media, websites
- Audience definition — who counts as a healthcare professional, KOLs and influencers
- Code mechanics — sanctions, complaints, training
- Cross-jurisdictional questions and the TGA interface
A note is cited by number and title — "NFTHD #95, Australian vs New Zealand shared assets" — and read as what it is: Medicines Australia's answer to a question, often after a complaint has turned on it, revised when the Code moves. Where a note names a complaint number, the adjudication itself is on the outcomes page of the main Medicines Australia site, not on the Tool Kit.
Code information sessions
Recorded sessions from Medicines Australia — Edition 20 briefings and topic sessions, hosted as video. Useful for onboarding; not citable as a source, since what is said in a session is not a published position. Cite the guidance document the session is explaining.
How to cite it
The Tool Kit's whole point is that it changes without a new edition of the Code. Four habits keep a citation honest.
Cite the Code for the obligation and the Tool Kit for the figure. "Hospitality must be moderate and reasonable, capped per person § 4.5(c); the cap is $140 per person per meal, excluding gratuities and GST (Hospitality and Venues Guidance, revised March 2025)." The number will change; the sentence that carries it will still be right.
Name the document and its date, not the page. A Tool Kit URL is a page that gets re-uploaded; a document is a name and a revision. "Promotional Claims Guidance, revised February 2026" tells the reader which five tests you mean if the Guidance is revised again.
Know which tier you are citing. A delegated document — the Standards, the cap, the complaints guidelines — can be cited as if it were the Code, because the Code says so. Interpretive guidance is Medicines Australia's view. A Help Desk note is an answer to someone else's question. A finding written up as "breach of NFTHD #52" is not a finding; the breach is of § 4.5(a), and the note is the evidence of how the clause is read.
Check the upload date before quoting a number. The Tool Kit's file paths carry the month they were last uploaded; when the date on the page and the date in the document disagree, the document has been replaced. Three things on this page moved in the last twelve months — the Promotional Claims Guidance (February 2026), the Transparency FAQs (March 2026) and the Verification Accompanying Report template (May 2026) — and none of them announced itself.
What is not on the Tool Kit
Four things people look for there and find elsewhere. The Code itself is on the same site, one level up, as an interactive text with a page per section — the section pages are the stable links for a citation. Complaint outcomes, the committee meeting dates and the how-to-complain page are on the main Medicines Australia site under the Code menu. Disclosure Australia — the searchable register that § 14.1(h) names — is its own site. And the Product Information, which every promotional claim is held to § OP 8, is the TGA's, on its eBusiness Services search. The Tool Kit tells you how to apply the Code; it does not hold the documents the Code is applied to.
Sources
- Medicines Australia — the Code Tool Kit
- Medicines Australia — Tool Kit guidance documents
- Medicines Australia — transparency reporting resources
- Medicines Australia — Notes from the Help Desk
- Medicines Australia — Working Together: Patients and Industry
- Medicines Australia — Code information sessions
- Medicines Australia Code of Conduct, Edition 20 — full text (PDF)