The well-being of patients is our primary consideration when promoting pharmaceutical products. We support health systems by providing information to our healthcare stakeholders, such as professional medical associations, patient advocacy groups, university clinics, and other healthcare providing institutions. We follow clearly defined internal approval requirements and procedures for each type of interaction, in line with applicable laws and codes. In countries with statutory or industry obligations on the disclosure of transfers of value to healthcare stakeholders, we comply with these obligations.
Direct-to-consumer advertising only in certain countries
Direct-to-consumer (DTC) advertising for prescription medicines is permitted in some countries, such as the United States. In line with applicable local laws, we use DTC advertising in these countries to help increase people’s awareness of certain diseases and the available therapies.
Roles and responsibilities
For all engagements with healthcare stakeholders, we have established internal policies and review processes and tools, such as record-keeping systems, to ensure adherence to statutory requirements and transparency obligations.
Our Global Regulatory Affairs unit has established a dedicated standard and corresponding process document on the review and approval of our promotional materials. At the operational level, the relevant business and all employees involved in our sales and marketing activities must adhere to our internal policies, standards and procedures. To ensure that all promotional materials meet our standards as well as local regulations end-to-end, we apply a harmonized Group-wide review and approval system.
Our commitment: Group-wide guidelines and industry standards
In addition to applicable laws and our own internal standards, we comply with the codes of conduct of various international and local industry organizations, such as the Code of Practice published by the International Federation of Pharmaceutical Manufacturers & Associations (IFPMA) and the Code of Practice of the European Federation of Pharmaceutical Industries and Associations (EFPIA) or the regulations of the U.S. Pharmaceutical Research and Manufacturers of America (PhRMA).
Moreover, we apply various specific internal rules and regulations:
- Pharma Code for Conducting Pharmaceutical Business and Pharmaceutical Operations (Pharma Code)
- Healthcare Ethical Guiding Principles
- Standard on Medical Activities
- Policy on Interactions with Patients, Patient Opinion Leaders, and Patient Organizations
- Guideline Good Practice and Process Guidance: Engagement with Patients, Patient Opinion Leaders, and Patient Organizations.
Transparent reporting
In 2021, we continued to publish financial and non-financial contributions that we made to healthcare stakeholders in the healthcare industry, such as healthcare professionals and healthcare organizations, as appropriate and in accordance with local laws and codes. The published information includes the names of individual recipients and their addresses as well as the purpose and amount of the transfer, as required by the applicable laws and codes. Before publishing, we secured all necessary informed consent forms, as required by the applicable data privacy regulations.
Regular employee training
In 2021, we continued with the international roll-out of our Code of Conduct-related training curriculum on dealing with dilemmas in healthcare-specific situations. Employees who are responsible for the promotion of our pharmaceutical products receive regular training on current guidelines. New employees participate in onboarding training dealing with the review and approval of promotional materials. Based on their roles and responsibilities and in order to remain up to date, employees participate in mandatory e-learning courses and classroom trainings on our policies and guidelines as well as important changes to the reporting requirements of transfers of value.