Engaging with Health Care Professionals
Ethical relationships with health care professionals are critical to our shared mission and vision to save and improve lives around the world.
An important part of achieving our mission is ensuring that health care professionals have balanced and accurate information about our products. All of our sales and marketing activities are conducted in accordance with our Guiding Principles for Ethical Business Practices Involving the Medical and Scientific Community. These principles are aligned with national regulations and worldwide industry codes, including the International Federation of Pharmaceutical Manufacturers & Associations Code of Practice and the World Health Organization’s Ethical Criteria for Medicinal Drug Promotion.
The guiding principles serve as a bridge between countries’ laws and regulations, industry guidelines, and our own Code of Conduct, enabling us to interact with the medical and scientific communities, to meet our ethical and legal obligations and to contribute to improvements in human health.
We provide promotional information in several ways, including:
- Product discussions between our professional representatives and health care professionals
- Promotional and/or educational meetings sponsored and organized by our company
We also provide non-promotional information through educational and scientific activities, including:
- Scientific presentations at medical conferences
- Support of independent continuing medical education
- Articles and related scientific studies published in peer-reviewed scientific journals
Our interactions and informational materials must provide truthful, balanced and non-misleading information to health care professionals. All of our interactions with health care professionals are highly regulated by governments through laws such as the U.S. Anti-Kickback Statute; the U.S. Food, Drug & Cosmetic Act; the U.S. Foreign Corrupt Practices Act; and anti-bribery laws in other countries.
Our company’s robust anti-bribery/anticorruption program and corporate prevention of bribery and corruption policy give our employees the awareness and knowledge to comply with applicable laws and regulations, and to understand that the company will not tolerate any act of impropriety. Our activities must comply with company policies as well as applicable laws, including the laws of the U.S. and other countries in which we do business.
Our program prohibits the offer, promise or giving of any payment or benefit at any time to an individual or entity for the purpose of improperly influencing decisions or actions with respect to our business. This policy applies to direct engagements (e.g., those conducted by our company) as well as to indirect engagements (e.g., those managed through a third-party intermediary or partner).
We conduct anticorruption/anti-bribery training across the company. Supplemental training is also provided for employees who engage with non-U.S. government officials.
Continuing Medical Education (CME) and Continuing Education (CE) programs
Our CME/CE Grant Program supports independent educational programs whose purpose is to maintain, develop or enhance the knowledge, skills and/or professional performance that health care professionals rely on to provide services for patients, the public or the profession. We are committed to ensuring that our CME/CE programs are educational and not promotional. Through them, we seek to increase physicians’ knowledge about the latest scientific data and health care topics, thereby improving patient care.
The environment in which we sponsor or support educational programs worldwide is complex, governed by a multitude of laws, regulations and medical or industry association guidelines. We are committed to honoring them all in the countries in which we operate.
CME programs that we support or sponsor are governed by an internal policy that is aligned with the appropriate standards and regulations to which the programs are held including, among other things, independence and financial disclosure.
- Grants of more than $500 made to U.S. organizations in support of independent, accredited educational programs for health care professionals
U.S. Medical Forums
We deliver balanced medical and scientific information to health care professionals within the U.S. through our company’s Medical Forums, which are conducted by external speakers. Speakers are selected on the basis of their expertise in the relevant subject matter. By attending one of our Medical Forums, health care professionals participate in interactive learning on therapeutic and health care industry topics. The goal of these interactions is to help attendees achieve improved medical results for their patients.
With our strict standards for conducting these Medical Forums, we comply with the PhRMA Code on Interactions with Health Care Professionals as well as with U.S. Food and Drug Administration (FDA) regulations, which assure that any product presentation is appropriately balanced with information regarding both the product’s potential benefits and its risks, and is consistent with approved product labeling.
- Payments made to U.S. medical and scientific professionals who speak on behalf of the company
Obtaining services from external health care professionals
We engage the services of external health care professionals only when we do not have the specialized talent or expertise internally, or when an external viewpoint is critical. We ensure that compensation provided to external health care professionals is fair and reasonable and is aligned with the fair market value of the service in the home country of the health care professional providing the service.
Prescription product samples
Where sampling is permitted, our company has established country-specific guidance and policies on providing prescription product samples to health care professionals. This guidance specifies the appropriate distribution and use of samples to safeguard against the potential for misuse or abuse of our products, or the diversion of our products to inappropriate channels.
In accordance with the law and with ethical practices, we do not provide product samples to reduce or discount the price paid or reimbursed, or in exchange for prescribing, purchasing or contracting for our products or for recommending our products for formulary status.
Unapproved or “off-label” use of our medicines and vaccines
In accordance with laws, regulations, internal policies and ethical practices, our professional representatives and other members of our sales and marketing team are not permitted to promote product uses that are inconsistent with the approved product label, sometimes referred to as “off-label” promotion. We have policies and training in place to address violations, and we ensure that physicians are aware that we do not encourage off-label use.