Incentive Management Guidelines

MEDIPRAGMA declares and guarantees to have the required technical skills, means and resources to organize and properly carry out a Market Research Project. The Cost Estimation is prepared according to the organizational criteria of MEDIPRAGMA.
MEDIPRAGMA undertakes to manage, at its own risk, the entire organization and conduction of the Market Research Project and to conduct to the highest standards, in full compliance with the statistic-scientific rules and rationales pursuant to the MEDIPRAGMA Project Protocol, in respect of the timing agreed upon and in strictly observance of any applicable regulation on the topic, including, by way of an example, the ones quoted hereby.
Moreover, MEDIPRAGMA ensures full compliance with the Esomar, EphMRA and Assirm Codes of Conduct as well as observance of the Legislative Decree 219/2006.
The management of project’s incentives abides by national and international regulations, as well as self-regulation rules established by market and social research in the Pharmaceutical industry.
The legal regulations shall be interpreted in conjunction with the professional codes of conduct related to social and market research for statistical and scientific purposes, and the Assirm Code of Conduct (specifically the Assirm Directive related to interviews involving medical staff) and the ICC / ESOMAR Code of Marketing and Social Research Practice.
Therefore, any incentive granted to the medical staff represents a reward to thank respondents for their participation, and shall not be the main reason for taking part in surveys.
Incentives must be neutral to the nature of the research project and its target in order not to influence respondents.
The recognition of the incentives is closely related to the formal participation in the survey, and is not subject to additional conditions.
The value of incentives is established according to MEDIPRAGMA organizational criteria. Cost estimations, without detailed and explicit criteria, are defined by MEDIPRAGMA.
The incentives publication on specific websites shall be subject to the authorization from the organizations the physicians work in, and to the explicit authorization (Privacy Law) of the recipient. Only if both authorizations are provided, incentives can be published online.

Disbursement Traceability
The incentives provided are analytically recorded according to the tracking of respondents / targets in compliance with the ISO 9001 and ISO 20252 standards as well as with Farmindustria regulations about transparency obligations.
Respondents may not be involved in research projects more than 4 times per year, with at least a three-month interval between each interview.
Refer to the corresponding forms (Mod. 1-07008 Incentives Management, Traceability) for further information.
In some particular Market Research Projects, incentives are granted in the form of a certain amount of money. In this case, a real consulting assignment is prepared (see attached Example Assignment Proposal - Mod. 4-02.004_M) in compliance with the current legislation about "incompatibility" and authorization to perform extra-institutional assignments for those who work in the public sector (see attached application forms: Mod 4-02.004b and 4-02.004c). The rate is thus paid only against appropriate tax document.
These rates are anyway monitored and maintained at a minimum level proportional to the quantity of time required and, in any case, do not exceed the normal hourly rate requested by physicians for professional advice.

Consent clause for traceability and disclosure to third parties
In compliance with traceability obligations ( ISO 9001 and ISO 20252), as well as with Farmindustria regulations about Transparency Obligations, incentives are being monitored and maintained at a minimum level based on the time required to participate in the survey. Moreover, they shall never exceed the normal hourly rate applied by physicians for professional consultancy.
We also require the receiver’s explicit authorization (Privacy Law) to disclose the incentive provided to third parties.