Pharmaceutical marketing is regulated by legislation worldwide. For instance, manufacturers in Germany are only permitted to advertise prescription drugs to medical professionals such as physicians and pharmacists. In doing so, they must always disclose the active ingredients, side effects, and contraindications of the advertised drug.
Our company commercializes both prescription medicines as well as over-the-counter products. In marketing our products, we voluntarily commit to various standards that exceed statutory regulations. Because patients deserve effective, high-quality treatment, they are always our primary consideration.
Guidelines and organization
We adhere strictly to all regulations on pharmaceutical marketing. Our Group-wide Pharma Code for Conducting Pharmaceutical Business and Pharmaceutical Operations defines the relevant standards for ethical marketing practices. This code also governs our interactions with physicians, medical institutions and patient advocacy groups. We furthermore comply with the codes of conduct of national and international industry organizations such as the Code of Practice and Code of Pharmaceutical Marketing Practices published by the International Federation of Pharmaceutical Manufacturers & Associations (IFPMA). Our pharmaceutical activities in the United States are governed by a specific US guideline.
All guidelines pertaining to marketing and advertising are part of our Group-wide compliance program, which stipulates that we always conduct business in compliance with the law and according to the highest ethical standards. We regularly review all guidelines, adapting them to new developments.
We have defined processes for all international, national and regional sales and marketing activities, and have appointed individuals responsible at each of these levels. We furthermore conduct regular audits of our sales and marketing activities.
High global standards for advertising materials
Through our Principles of Review and Approval of Promotional Materials and Other External Communications, we ensure that all advertising materials meet our rigorous standards. In 2016, we updated these principles and rolled out a Group-wide review and approval system that meets the latest technical requirements. This system helps us check whether all advertising materials meet our standards. All employees involved in creating advertising materials worldwide have been trained on the updated principles as well as this new system.
Direct marketing only permitted in certain countries
Direct-to-consumer advertising (DTC) for prescription drugs is allowed in some jurisdictions such as the United States and New Zealand. We only pursue DTC campaigns in these countries. Through direct advertising, we hope to increase people’s awareness of certain diseases as well as available therapies, empowering consumers and patients to make informed decisions about their treatment.
The industry associations in which we are members have put in place various reporting channels for people to report any wrongdoing with regard to marketing practices.
Furthermore, we have also established a SpeakUp Line, which allows our employees to anonymously report potential compliance violations. If our marketing or advertising rules of conduct are violated, we have a committee in place to take immediate corrective and, if need be, punitive action.
We are a member of the German Association of Voluntary Self-Regulation for the Pharmaceutical Industry (FSA), which has defined its own code of conduct for collaboration between physicians and the industry. When violations of the FSA code are suspected, members and third parties can file complaints directly with an arbitration board. In 2015, we were involved in proceedings that resulted in a fine.
Regular employee training
Individuals responsible for our pharmaceutical advertising, as well as employees working in sales, marketing and regulatory positions, receive regular training on our current guidelines. Furthermore, via our Intranet the responsible employees also have access to our compliance guidelines on the marketing and promotion of pharmaceuticals.
We approach the marketing of our chemical products with the deepest sense of responsibility. For instance, we only supply our chemicals to commercial customers with proven expertise and furthermore provide them with detailed information on the safe handling and use of our products. We have an extensive safety and security network in place to prevent the misuse of dual-use products. This network features standardized export control guidelines for these products, which are monitored by our central Export Control & Customs Regulations unit, as well as by trade and export control officers at our local subsidiaries. If we suspect misuse, we terminate our business relationship with that customer.