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:
- 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.
- 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.
- 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).
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