22-05-2013 EPPA memo on EFPIA Disclosure Code

Over the past years the pharmaceutical industry has committed itself to working towards a greater transparency, accountability and ethical behavior within an industry framework of self-regulation.

In itself a good development, that is completely in line with the European Commission’s Ethics & Transparency Initiative, to establish equal relations between all stakeholders of the pharmaceutical industry that are based on mutual trust and transparency. One of the results of this initiative lead to the List of Guiding Principles Promoting Good Governance in the Pharmaceutical Sector.

The European Federation of Pharmaceutical Industries and Associations (EFPIA), which is one the members of this platform, adopted and translated these principles to the EFPIA Code on the Promotion of Prescription-only Medicines to, and Interactions with, Healthcare Professionals (HPC Code). The Code describes many principles advocating ethics and transparency in the sector, and also includes an article regarding gifts (article 10). The article states that “inexpensive” gifts are allowed for promotional purposes and the Members Associations of EFPIA shall provide guidance on the meaning of the term “inexpensive”.
The fact that the Members Associations have the final saying in defining the term inexpensive, has created most concerns within our industry over the past month(s). As we were informed that the German pharmaceutical association has the intention to completely ban the use of promotional products to avoid confusion and increase transparency. EPPA is convinced that a complete ban is not the answer is establishing more trust and transparency. If pharmaceutical companies are deprived of the possibility to use promotional products as a highly effective and affordable communication tool they will be forced to spend significantly more on marketing. This will have a negative effect on price, putting pressure on both the relationship with the public health services and ultimately the publics’ perception of the pharmaceutical industry in total.
Therefore, EPPA has formally addressed the EFPIA Director General, Mr. Bergström, to get involved in defining the term “inexpensive”. We are convinced it would be best to pan-European define the term, instead of leaving it up to the Members Associations in the several European countries. This will, in our opinion, only create misunderstandings.

Further, EPPA has also addressed all the EFPIA Member Associations and Affiliated Members requesting their support to pan-European define the term “inexpensive”. Through reliable sources we understood that most pharmaceutical companies are not even aware of the adjusted principles of the HPC Code and the consequences this potentially has for their business.

The EFPIA Code still needs to be formally adopted at the EFPIA Annual Meeting on June 24-25. EPPA feels confident we will meet with Mr. Bergström before that date to discuss this matter. We will of course keep you updated on the procedures.

Relevant articles and reading material: