Indirect Channel HCP/GO Travel & Hospitality Policy

 1 . Air Travel

a) Period of travel. Air travel arrangements provided to Healthcare Professionals (HCPs)/Government Officials (GOs) to attend an event should not cover a period of stay beyond the official duration of the Event. HCPs/GOs should not be flown in any earlier than the day before the Event starts and depart no later than the day after the Event finishes.

b) Personal travel. Indirect Channel may not facilitate (e.g. arrange, book, pay) itself or by directing its third-party service providers, any personal travel arrangements or expenses for or incurred by the HCP/GO.

c) Travel class. The maximum class of travel permitted for HCP/GO flights. 

d) All air travel must be booked on commercial air carriers.

2. Accommodation
Accommodation may be provided to an HCP/GO in situations where the following conditions are met:

a) Period of stay. Only the nights required in order for the HCP/GO to attend the Event can be provided. Overnight stays should start no earlier than one night before the Event begins and end no later than the night of the final day of the Event.

b) Appropriate hotels. The hotel must be reasonable and modest, generally a standard single occupancy room at a reasonable rate (typically 4 star hotels are appropriate).  5 star hotels or hotels considered boutique or top tier should be avoided.

c) Appropriate locations. The hotel should be located in close proximity to the facility where the Event is being held. The hotel should not be in a location primarily known for resort, vacation or leisure facilities (e.g. Ski & beach resorts). Hotel room and tax amounts will generally be prepaid by Indirect Channel.  The HCP/GO should provide a personal credit card for incidentals.
 

3. Meals
A meal may be provided to an HCP/GO where the following conditions are met:

a) Legitimate business purpose. The meal is provided in conjunction with an Event. Meals must not serve as a social occasion (no “wining and dining”).

b) Reasonable & modest. The meal is modest and reasonable (not at a top-end or top-tier restaurant). The appearance and image of the restaurant / Event and how it might be perceived by the public should be considered. As a reference, please see Picture 1 for an overview of limits for meals with hcps that Stryker uses and deems to meet these requirements.

c) Occasional. The meal is occasional and is not held more often than necessary. For example it may be inappropriate to have a “standing” weekly dinner arrangement with an HCP/GO.

d) Subordinate to content. The meal is subordinate (less than) in time and focus to the Event content. 

e) Appropriate venue. The location and venue of the meal is conducive to the transmission of scientific, educational or commercial content. For larger groups a private room should be considered. Locations with dancing, loud/live music, live sports, or other entertainment may not be considered appropriate.  Appropriate locations include a hotel conference room, a private dining room or quiet table in a restaurant, a Stryker facility, or the HCP’s/GO’s office.

f) No entertainment. The meal is not part of and does not involve an entertainment or recreational event.

g) Genuine professional interest. The meal is provided only to HCPs/GOs with a genuine professional interest in the Event. Meals must not be provided to spouses, guests or employees of HCPs/GOs or any other person who does not have a genuine professional interest in the Event.

h) Room and audio video costs. Associated costs, including room and audio visual hire, should be clearly separated from the meal costs.

I) No bar hopping. A business meal (whether dinner, lunch or breakfast) should not take place in more than two locations per meal. It is not acceptable to “bar hop” with an HCP/GO.

j) Drinks. Occasionally it may be appropriate to have a drink with an HCP/GO in connection with an Event. Care should be taken when considering venue and amount and quantity of drinks to ensure that it does not create an appearance that the interaction is a social gathering. 

4. Ground Transportation

Indirect Channel can provide reasonable round-trip ground transportation required for the HCP/GO to attend the Event.  Ground transportation may include
taxi or car services. If the HCP/GO uses a personal automobile, Indirect Channel may pay the commonly accepted statutory mileage reimbursement rate.

Up to first class commuter train travel is permitted in Europe. 

Mid-size class car rental is permitted. 

Indirect Channel can pay for parking charges incurred by the HCP/GO to attend the Event.

5. Personal and entertainment expenses

Personal expenses are the responsibility of the HCP/GO. They include, but are not limited to: minibar expenses, movies, and incidentals.

Laundry services will only be reimbursable where incurred as part of an extended Event (one week or more).

Entertainment expenses are the personal responsibility of the HCP/GO. Indirect Channel cannot facilitate the arrangement, booking or payment of any entertainment for the HCP/GO.  This includes, but is not limited to skiing, golf, tennis, boating, museums, sightseeing, city tours, sport and cultural events.

6. Expenses for spouses or guests of HCPs/GOs

Indirect Channels (or any other person or company representing Indirect Channel like a travel agency) may not facilitate (e.g. arrange, book and/or pay for) any travel, accommodation or other expenses for spouses, children or guests of the HCP/GO or for any other person who does not have a bona fide professional interest in the information being shared at the Event.