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Code of Conduct - Question & Answers

1. Guiding Principles - March 2006

Question 1:
Under what conditions is it appropriate to play golf with a health care professional (HCP)?  Can a member company pay for its representative's round(s) of golf? 

Response:
Member companies employees may play golf with health care professionals, subject to the Guiding Principles of Rx&D. Namely,

  • No monetary or other consideration is to be given to health care professionals for the purpose of gaining access or influence;
  • The only acceptable form of hospitality for health care professionals are modest meals and/or refreshments; and
  • All interaction with health care professionals is to be conducted in a highly professional, business like, and ethical manner.

Therefore, member companies cannot pay or subsidize (either directly or indirectly) golf for HCPs.

In regard to the payment/subsidization of employee golf, this is a matter for individual company policy resolution. Once again, member companies must be mindful of the third Guiding Principle listed above.

For more details, please refer to CEO Bulletin 02/06 (January 17, 2006)

Question 2:
Can you please define what constitutes medical equipment for the purpose of the recent CEO Bulletin concerning the lending of medical equipment and when it would be appropriate to lend such equipment? Can you specify the role of member representatives in the establishment and implementation of these programs?

Response:

  1. Given the innovative nature of research in medicine, it would be difficult to establish an exhaustive list of what properly constitutes medical equipment. Members, however, should be guided by the spirit of the Code and, in particular, the commitment to “conduct and sponsor scientific research in order to develop knowledge that will benefit Canadians.” Therefore, members should be guided by the notion that the specialized medical equipment that is necessary to conduct such scientific research would constitute the medical equipment that is eligible for lending.
  2. In regard to the appropriate circumstances for the lending of such equipment, members should evaluate their program in light of their commitment to obtain the appropriate inputs into their research design. In the process of this determination, members must keep in mind that medical equipment loan programs cannot, under any circumstances, be conditional upon the prescription of medicines, or designed for the purposes of gaining access or influence over HCPs.
  3. Members' field-based sales personnel can be involved in the establishment and implementation of these programs insofar as they are not involved in the design and evaluation of the research program. This is consistent with Section 9.2.4 of the Code:”Other member representatives' roles in the process must be limited to the distribution and collection of materials pertinent to the study, on behalf of the medical/scientific department.”

These answers are consistent with the International Federation of Pharmaceutical Manufacturers Associations' Code of Pharmaceutical Marketing Practices, particularly Sections 2.2 (Independence of Healthcare Professionals) and Section 7.6.4 (Items of Medical Utility).

Revised: June, 2006
 
 
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