Code of Conduct - Question & Answers

7B. Hospitality – February 2007

Question 1:
I am writing you as the president of XX Association. I have a question regarding the policies of Rx&D and a soirée that we would like to host in our area.

In the past, the association (85 members from all Rx&D member companies) has organized a cocktail (5 à 7) to thank the secretaries of the medical clinics for their invaluable cooperation.

This cocktail took place during Secretaries Week (week of April 23) and was financed from the revenues earned from the sales of the representatives’ directory.

Under no circumstances were pharmaceuticals mentioned during this event. The cocktail did not benefit any specific company. The sole benefit was a better working relationship between the representatives and the secretaries.

The secretaries are essential allies for the medical representatives. Without them, our work would be much more difficult.

As an association (with no company affiliation), we feel that it would be a good idea to re-introduce this great tradition. We would therefore like to know if the 2007 rules of Rx&D allow us to:

- Host a cocktail for medical clinic secretaries
- In a hall that is isolated from the “public eye”
- Funded by the revenues from the association directory

Response:
Inasmuch as members of the XX association are employees of Rx&D members, the Code of Conduct is applicable. It is important that the members of this association understand that the public is unlikely to draw a distinction between the XX association and Rx&D.

The Code is clear in regard to gifts or hospitality to staff of health care professionals (HCP). Section 7A (Gifts) states that “Members must not offer to...any member of a health care professional’s clinical/administrative staff, any gift…or any promotional aid, prize, reward, or any other item which is intended for personal/family benefit, or pecuniary advantage.”

If one were to choose to see this as a hospitality event, Section 7B.1 (Hospitality) is equally clear: “The primary objective of the hospitality should be to create the appropriate venue and interaction. Hospitality should not be utilized as the primary access to meet with health care professionals, but as an opportunity to expand the business discussions.”

The 5 à 7’s primary purpose is the hospitality. This is contrary to Section 7B.1.2: “In all instances, the provision of refreshments/meals must be clearly incidental.”