Catering costs under the compliance lens
The pharmaceutical industry is under special scrutiny when cooperating with healthcare professionals or organising educational events. Hospitality is therefore a sensitive area that must be managed in full compliance. Code violations can lead not only to reputational damage but also to serious competition law consequences.
We’ll show you what matters under the current codes
- Catering may only be provided for internal training events or working meals. At external training events, catering may only be provided under very limited circumstances.
- It should be appropriate in scale and socially suitable. The codes specify that catering must not be used to incentivise participants or be overly lavish.
- As a rule, catering for accompanying persons is not permitted.
- What is essential is clear documentation showing who was catered for, on what occasion and what was provided. Failing to document catering can put you in breach of the codes.
Guidance on catering limits and appropriateness
Due to rising costs, the FSA in Germany has increased the catering limit from 60 to 75 euros per person.
In Austria and Switzerland, higher flat rates apply, based on different time parameters. Typical permitted catering at external events such as congresses includes coffee, tea, water, light refreshments, and snacks or pastries. Anything that could be considered excessive – such as alcohol, lavish menus, or gourmet catering – is problematic.
Practical tips for compliant catering
- Clarify if an event is internal or external Catering may only be provided directly by the pharmaceutical company for internal training events or working meals. In the case of external events, the purpose must be clearly professional, the group kept small, and the role of catering clearly defined.
- Define the purpose and participant group Catering should be provided for events with a clear professional purpose – for example, presentations, discussions or workshops – and not be mainly for social purposes.
- Check and set cost limits Ensure that per-person catering costs do not exceed the customary national limits, as specified by codes. Any higher costs in exceptional cases should be carefully documented and justified.
- Maintain transparent documentation Record who was catered for, on what occasion and in relation to which element of the programme. Retain all relevant records and receipts for at least five years.
- Avoid incentives and conflicts of interest Catering must not be used to influence decisions on appropriate therapies, prescriptions or procurement. It must also not be seen as an incentive to attend the event.
- Establish internal approval processes Define clear approval processes to determine who decides on the catering budget, type and scope, and who selects the restaurant or catering provider.
Summary: Catering costs for pharmaceutical training events may be covered, but only under strictly defined conditions. What matters is that catering has a clear professional purpose, is appropriate in scale, and is properly documented and transparent. Thoroughly understanding these rules minimises compliance risks and safeguards trust in your training programmes.
We’ll be happy to support you with internal training to give your staff the know-how for compliant catering.
"Make sure you follow the rules, and keep things in proportion while covering participants’ needs. Only compliant arrangements are truly sustainable for your company.”
Sarah Huch | Compliance Officer and Head of Business & Process Development