Luye Pharma Ltd: Methodological note for HCP/ORDM/HCO disclosure 2025

Version: 06.03.2026
Country: United Kingdom
Data year: 2025
Year of publication: 2026

ABPI platform and a link to the web page may be accessed here; https://www.abpi.org.uk/reputation/disclosure-uk/.

1 Definitions

1.1 Recipients

Recipients include Healthcare Professionals (HCPs), Healthcare Organisations (HCOs), and Other Relevant Decision Makers (ORDMs) in the United Kingdom. Luye Pharma Ltd interacts with these groups for activities such as speaking engagements, advisory boards, training, publications, and consultancy services.

1.2 Kind of ToVs

Transfers of Value (ToVs) include:

Our disclosure includes: Payments and benefits in kind to HCPs and ORDMs, Transfers of value to HCOs, including: Donations and grants.

2 Disclosure’s Scope

2.1 Products concerned

All Luye Pharma Ltd medicinal products marketed or supported in the UK are included. ToVs are disclosed irrespective of product or therapeutic

2.2 Company concerned

This methodological note applies to Luye Pharma Ltd, including ToVs made directly or via third-party vendors acting on behalf of the company.

2.3 Excluded ToVs

Luye Pharma Ltd does not disclose payments for any medicines provided on request. Payments made to homecare providers fall outside the scope for disclosure.

2.4 ToVs date

The date recorded is the date the payment was processed by Luye Pharma Ltd. For financial grants the date of the payment has been recorded as the date the payment was processed

2.5 Direct ToVs

Direct ToVs include payments made directly by Luye Pharma Ltd to HCPs, HCOs, or ORDMs for contracted services or sponsorship

2.6 Indirect ToVs

Where the payment has been provided by Luye Pharma Ltd or a third-party from outside the UK, the ToV is recorded in the local currency and converted to GBP Sterling (£) using the spot rate during the month of engagement. All payments are reconciled against the contractual agreements, the tracker recordings and the actual payments made.

2.7 Non-monetary ToVs

Non-monetary ToVs include benefits in kind such as travel, accommodation, and meeting sponsorship, valued at fair market value.

2.8 ToVs in case of partial attendances or cancellation and refund

Where an HCP, HCO, or ORDM partially attends the involved event, the ToV is recorded at the pro-rata value of the services delivered. In the case of cancellation or refund, any ToV already disclosed is adjusted in the subsequent publication cycle to reflect the net amount actually retained.

2.9 Cross-border activities

For cross-border activities involving HCPs, HCOs, or ORDMs outside the UK, ToVs are disclosed in the jurisdiction where the principal engagement takes place, in line with the applicable national code. In the UK, only ToVs related to UK-based recipients or UK-based activities are disclosed through the UK ToV platform.

2.10 R&D

ToVs related to research and development (R&D) activities (e.g., grants, investigator-initiated research, clinical trials) are included in the disclosure if they constitute a transfer of value to HCPs, HCOs, or ORDMs. Such payments are reported at the net value after deduction of VAT where applicable, in line with ABPI/EFPIDom guidance.

2.11 Voluntary disclosure

Luye Pharma Ltd voluntarily discloses payments to members of the public (patients, journalists) on its company website. “We Luye Pharma Ltd have disclosed all payments of value to members of the Public including to patients and journalists on our company website”.

3 Specific considerations

3.1 Country unique identifier

Each disclosed record is assigned a country-specific unique identifier in line with the ABPI platform requirements. This identifier links the ToV to the relevant HCP, HCO, or ORDM within the UK ToV reporting system.

3.2 Self-incorporated HCP

Where an HCP operates through a self-incorporated practice or company, the ToV is disclosed under the name of the individual HCP, and the legal entity (if relevant) is indicated in the platform where possible, consistent with the ABPI template.

3.3 Multi-year agreements

For multi-year agreements, each payment is disclosed in the calendar year it is processed, rather than attributing the entire contract value to the first year. The disclosure clearly reflects the annual payment amounts rather than the total contract value.

3.4 Country specificities

As part of our commitment to transparency and openness about our activities and to meet the requirements of the Association of the British Pharmaceutical Industry (ABPI) Code of Practice, we Luye Pharma Ltd have disclosed all payments of value to members of the Public including to patients and journalists on our company website. Payments or benefits received by HCPs, HCOs, and ORDMs during the 2025 calendar year will be disclosed on a central platform managed by the ABPI and made public in 2026

3.5 Quality Checks

Luye Pharma Ltd performs regular quality checks on ToV data, including:

  • Reconciliation between contracts, attendance records, and payment ledgers.
  • Validation of beneficiary details (HCP, HCO, or ORDM classification).
  • Spot checks and internal audit reviews to ensure completeness and accuracy prior to publication.

4 Data protection legal basis

4.1 Consent collection

Where required, by data protection law, explicit consent is collected from HCP’s, HCO’s, ORDM’s and other recipients prior to the disclosure, in line with ABPI and EFPIA guidance.

4.2 Legitimate interests

Luye Pharma Ltd has adopted legitimate Interest as the lawful basis for processing data for disclosure purposes subject to an appropriate balancing test and privacy-impact assessment.

5 Form of disclosure

5.1 Date of publication

Disclosures for the 2025 data year will be published in 2026

5.2 Disclosure platform

As part of our commitment to transparency and openness about our activities and to meet the requirements of the Association of the British Pharmaceutical Industry (ABPI) Code of Practice, we Luye Pharma Ltd have disclosed all payments of value to members of the Public including to patients and journalists on our company website. Payments or benefits received by HCPs, HCOs, and ORDMs during the 2025 calendar year will be disclosed on a central platform managed by the ABPI and made public in 2026

5.3 Disclosure language

English

6 Disclosure financial data

6.1 Currency

GBP £

6.2 VAT included or excluded

VAT treatment follows ABPI guidance; typically, VAT is excluded unless otherwise required.

6.3 Calculation rules

ToV’s in foreign currencies are converted to GBP using the spot rate during the month of engagement.”

“All payments were reconciled against the contractual agreements, internal trackers, and actual payment records to ensure accuracy detail

7 Additional Information

Luye Pharma Ltd operates a compliance and onboarding process to assess, screen, validate, and monitor all interactions with HCPs, HCOs, ORDMs, and members of the public. All such interactions are conducted in accordance with applicable laws, industry codes, and internal policies on transparency and integrity.

Where an In-Scope Organisation has determined that the measure applies to the procurement, suppliers wishing to bid for that contract are required at the selection stage to submit a Carbon Reduction Plan which details their organisational carbon footprint and confirms their commitment to achieving Net Zero by 2050. 

Carbon Reduction Plans are to be completed by the bidding supplier1 and must meet the reporting requirements set out in supporting guidance and include the supplier’s current carbon footprint and its commitment to reducing emissions to achieve Net Zero emissions by 2050. 

The CRP should be specific to the bidding entity, or, provided certain criteria are met, may cover the bidding entity and its parent organisation. In order to ensure the CRP remains relevant, a Carbon Reduction Plan covering the bidding entity and its parent organisation is only permissible where the detailed requirements of the CRP are met in full, as set out in the Technical Standard2 and Guidance3, and all of the following criteria are met: 

  • The bidding entity is wholly owned by the parent; 
  • The commitment to achieving net zero by 2050 for UK operations is set out in the CRP for the parent and is supported and adopted by the bidding entity, demonstrated by the inclusion in the CRP of a statement that this will apply to the bidding entity; 
  • The environmental measures set out are stated to be able to be applied by the bidding entity when performing the relevant contract; and 
  • The CRP is published on the bidding entity’s website. 

Bidding entities must take steps to ensure they have their own CRP as soon as reasonably practicable and should note that the ability to rely on a parent organisation’s Carbon Reduction Plan may only be a temporary measure under this selection criterion. 

The Carbon Reduction Plan should be updated regularly (at least annually) and published and clearly signposted on the supplier’s UK website. It should be approved by a director (or equivalent senior leadership) within the supplier’s organisation to demonstrate a clear commitment to emissions reduction at the highest level. Suppliers may wish to adopt the key objectives of the Carbon Reduction Plan within their strategic plans. 

A template for the Carbon Reduction Plan is set out below. Please complete and publish your Carbon Reduction Plan in accordance with the reporting standard published alongside this PPN. 

Supplier name: Luye Pharma Ltd 

Publication date: 27-August-2025

Commitment to achieving Net Zero 

Luye Pharma Ltd is committed to achieving Net Zero emissions by 2050. 

Baseline Emissions Footprint 

Baseline emissions are a record of the greenhouse gases that have been produced in the past and were produced prior to the introduction of any strategies to reduce emissions. Baseline emissions are the reference point against which emissions reduction can be measured.

Baseline Year: 1 July 2022 – 30 June 2023 
Additional Details relating to the Baseline Emissions calculations. 
Baseline year emissions: 1 July 2022 – 30 June 2023 was the most recent full year of carbon emissions data. 
EMISSIONS TOTAL (tCO2e) 
Scope 1 
Scope 2 0.37548516 
Scope 3  (Included Sources) 378.344 
Total Emissions 378.7195 

Current Emissions Reporting 

Reporting Year: 1 July 2024 – 30 June 2025
EMISSIONS TOTAL (tCO2e) 
Scope 1 
Scope 21.309252
Scope 3
(Included Sources) 
342.4977
Total Emissions 343.8069743

Emissions reduction targets

Luye Pharma Ltd is an expanding business with new products and employees planned which will be a challenge initially in carbon reduction. Luye are committed to achieving Net Zero emissions by 2050 and will work towards limiting carbon emissions during this expansion.

Carbon Reduction Projects

Completed Carbon Reduction Initiatives

The following environmental management measures and projects have been completed or implemented prior to the 2022/23 baseline.

Scope 1

Company Facilities: Luye Pharma Ltd are a homebased Company with office space leased on The Surrey Research Park who have prepared a sustainability plan and target of Carbon Net Zero by 2030.

They continue to improve their facilities this includes the list of interventions below;

  • The installation of LED lighting
  • occupancy/motion sensors
  • air source heat pumps (ASHP)
  • heat recovery and the removal of fossil fuel heating systems.

These interventions have helped achieve the improved performance of their buildings to 85% now achieving an EPC rating of A-C.

Battery Electric Vehicle (BEV) charging points are available on site.

This data would be reported by The Surrey Research Park and will be excluded from this to avoid double reporting.

Company Vehicles: we do not have any company vehicles, so there are no emissions from this category included in our emissions data

Scope 2

Purchased electricity, steam, heating and cooling for own use: we don’t purchase any of the energy needed for our buildings as they are all leased and are covered by the landlord. 

3 homebased employees 

Scope 3

Category 4 and 9 upstream and downstream distribution

As planned deliveries of product to pre-wholesaler are now consolidated including new product launches. 

Our main wholesaler now maintains minimum stock levels and optimises deliveries from pre wholesaler. 

An ESG statement from our pre-wholesaler is currently in progress for future CRP’s. 

Category 5 waste generated in operations 

All outers/shippers/shrink wrap is recycled by pre-wholesaler. 

Pallets are reused by pre-wholesaler unless damaged, any damaged pallets are returned to their supplier to be recycled. 

Livery: 

Folding box and leaflet: no recycled paper is used 

Label: the pulp for this paper comes from FSC® certified forest management.  

Category 6 business travel – 3 employees + 5 contractors 

Meetings are held via Teams/Zoom with face-to-face meetings kept to a minimum. 

Travel is via road and air with some hotel stays mainly within the UK with occasional European. 

Luye continues to grow with attendance at a variety of Conferences and meetings with 3rd Party Marketing Company. Public transport used or EVs 

Category 7 employee commuting – 3 employees 

Luye Pharma Ltd are a homebased Company with office space leased on The Surrey Research Park. Travel to the office is limited with team meetings approx. 1 – 2 times annually. 

Travel is using EV’s. 

In the future we hope to implement further measures such as: 

Scope 2: 

Encourage employees /contractors to use 100% renewable electricity energy suppliers. 

Scope 3: 

Category 4 and 9 upstream and downstream distribution: 

Continue to consolidate supply chain to reduce product shipments to pre wholesaler including new launches. 

Continue to work with main wholesaler to maintain/increase minimum stock levels and optimise deliveries from pre-wholesaler, extend to other customers. 

We will continue to partner with logistics suppliers who prioritise their own environmental impact including GEODIS who have an option to adopt their Air & Sea Sustainable Fuel solution. 

Category 5 waste generated in operations: 

Integrate sustainability into product packaging and design. 

Category 6 business travel and Category 7 employee commuting 

Maintain Home Working model; where possible limit business travel and commuting, including continued use of video conferencing, to achieve sustainable long-term reduction of our CO2 emissions. 

Employee learning and behaviour change 

Luye Pharma will continue to raise environmental awareness with all employees/contractors; suppliers and customers, encouraging better energy use and reduced waste. 

Declaration and Sign Off 

This Carbon Reduction Plan has been completed in accordance with PPN 06/21 and associated guidance and reporting standard for Carbon Reduction Plans. 

Emissions have been reported and recorded in accordance with the published reporting standard for Carbon Reduction Plans and the GHG Reporting Protocol corporate standard4 and uses the appropriate Government emission conversion factors for greenhouse gas company reporting5

Scope 1 and Scope 2 emissions have been reported in accordance with SECR requirements, and the required subset of Scope 3 emissions have been reported in accordance with the published reporting standard for Carbon Reduction Plans and the Corporate Value Chain (Scope 3) Standard6

This Carbon Reduction Plan has been reviewed and signed off by the board of directors (or equivalent management body).  

Signed on behalf of the Supplier: 

Name: Andrew Farrant 

Role: General Manager

Date: 27-Aug-2025 | 07:36:06 PDT

  1. Bidding supplier or ‘bidding entity’ means the organisation with whom the contracting authority will enter into a contract if it is successful.  ↩︎
  2. Technical Standard can be found at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/991625/PPN_0621_Technical_standard_for_the_Completion_of_Carbon_Reduction_Plans__2_.pdf  ↩︎
  3. Guidance can be found at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/991623/Guidance_on_adopting_and_applying_PPN_06_21___Selection_Criteria___3_.pdf  ↩︎
  4. https://ghgprotocol.org/corporate-standard ↩︎
  5. https://www.gov.uk/government/collections/government-conversion-factors-for-company-reporting ↩︎
  6. https://ghgprotocol.org/standards/scope-3-standard ↩︎