Policies that regulate Hikma colleagues' interactions with health care professionals in the United States reflect our commitment to compliance with applicable federal and state laws and regulations. We review and revise our policies as we deem appropriate to meet the requirements of a highly regulated and complex health care environment. California SB 1765 (California Business & Professions Code 119400, 119402) requires pharmaceutical companies to set an annual aggregate limit on certain promotional expenditures provided to a medical or health care professional as defined under the statute. Hikma has determined that the annual aggregate limit on covered promotional expenditures is set at $1,500 per covered medical or health care professional for annual periods commencing on May 1, 2015. This limit may be revised by Hikma from time to time. The foregoing limit does not represent a usual, customary, average, or typical amount for medical or health care professionals.
The statute excludes covered promotional expenditures, such items as drug samples given to medical or health care professionals intended for free distribution to patients, financial support for continuing medical education forums, financial support for health educational scholarships, and payments made at fair market value for legitimate professional services provided by health care professionals.
This annual aggregate limit is based on an estimate of the maximum value of gifts, promotional materials, and other items or activities as defined herein that a medical or health care professional may receive in 1 year. In setting this limit, we have taken into account the size of the Company and the size of its product portfolio.