A transfers-of-value extract the Code owner will initial

Transfers of value leave a paper trail that outlives the representative who ate the sandwich. If last year’s disclosure lists a hospital that no longer sits on the plate, someone will ask why money went there. If the plate lists a trust that never appears in finance, someone else will ask why the field still calls.

We do not replace your disclosure process. We put the extract beside the geography and mark mismatches. Typical causes: old legal names, payments booked to a holding company, and a meeting held in a hotel that finance coded as “London” while the attendees were a named trust’s department.

Bring the extract to the briefing. Redact personal names if your policy requires it; keep the organisation strings. We cannot reconcile a file that only says “various HCPs”.

The companion will list the mismatches in a table. It will not tell you which ones are innocent. That judgement stays with the Code owner.