Running sales meetings in line with the ABPI Code of Practice
(Published 02 April 2004)

The main requirement for company organised or sponsored meetings is that they must be primarily educational activities, rather than social events. Hospitality can be provided, but it must comply with Code requirements in relation to cost, form and appropriateness to the occasion and to the attendees. The principle is that there should be no suggestion that doctors are being ‘wined and dined’ by pharmaceutical companies and hence being unduly influenced in favour of their products.

The Code requires that all companies have a written policy on meetings and hospitality, which should be provided to representatives. You should consider all of the following in conjunction with your company’s policy.

Arrangements

The first point to consider when organising a meeting is that it must have clear educational content. ‘Educational content’ can be judged in terms of its quality, quantity and relevance to the attendees. CDP approval is good evidence of acceptable educational content but promotional presentations can also be considered, in this sense, as ‘educational’

The next step is, that whatever the ‘educational content’, this must be, and must be seen to be, the main purpose of the meeting. It obviously follows that hospitality therefore must be secondary. In getting the right balance between education and hospitality, you need to consider the time spent on each and the ‘attractiveness’ of each. The attractiveness of the education will be determined by such things as the topic and the speaker(s); the attractiveness of the hospitality will be determined by such things as the venue and the perceived cost.

The impression is just as important in this as the reality so it is important that all material associated with the meeting e.g. invitation, programme, poster etc should focus primarily on the educational component, rather than on the hospitality.

Meetings should only be attended by health professionals and administrative staff for whom the educational content is relevant. Accompanying persons should not normally be invited to attend meetings, but it they do attend, all costs must be paid for by the persons they are accompanying.

The venue for a meeting must be professional and appropriate to the occasion. The educational part of the meeting should always be held in private. This means a private room in a restaurant, unless the restaurant has been booked exclusively for the meeting. You must be able to justify all the arrangements - is it really necessary for everyone to travel the distance involved?

Similarly, hospitality must be appropriate to the occasion e.g. a simple sandwich lunch with a product presentation to a GP practice, a buffet meal following an evening presentation by an external speaker. Hospitality must also be appropriate to the attendees, and the Code defines this as no more than the attendees would be expected to pay for themselves. Finally, hospitality must be justified by the arrangements for the meeting e.g. is an overnight stay essential, or could the meeting be reorganised to be completed in the same day?

Any activities offered as part of the meeting must be ‘professional’. This rules out any sporting activity, either as a participant or as a spectator. Casino evenings and wine tastings are also considered unprofessional.

Meeting materials

All materials associated with the organisation or content of a company meeting must comply with the Code e.g. invitation, programme, poster. This applies whether these are produced by you, or by third parties, such as an external chairman. It is strongly recommended that all meetings, however small or informal, should be documented in some way e.g. an invitation, a brief agenda.

All meeting materials must clearly state that your company has sponsored the meeting - this applies whether the meeting is promotional or educational - and, if the materials mention a product, P.I. should be included.

Promotional stand

You can only have a stand at a meeting which complies fully with the Code. This applies even if you are not directly responsible for the organisation of the meeting. Make sure you have permission from the venue for the stand and that you use only approved promotional material. Be particularly careful if you are making samples available from the stand - ensure that signed requests are always obtained and that samples are never left unattended.

Presentations

Any presentation you make must comply with the Code. You should therefore only use material which has been provided to you by your company as this will have been approved and certified to ensure that it complies with the Code. Follow instructions about providing Prescribing Information which usually will mean that you have to have copies of P.I. available at the meeting for any product you are promoting.

Technically, your company is responsible not only for your presentations, but also for presentations by external speakers. It is not usually possible to have a speaker’s presentation approved before a meeting, and speakers are entitled to express their own opinions, but you should be aware if it is likely that the speaker will not stay within the Code. You cannot select a speaker just because he is a supporter of your product, unless his support can be substantiated by data.

Acceptable Payments

• Meal(s) for attendees as justified by the programme
• Travel costs for attendees, if the meeting takes place outside their normal working area.
• Accommodation for attendees, if justified by programme
• Honoraria to speakers, meals and accommodation if justified by programme.

Unacceptable Payments

• Travel costs for local meetings
• Accommodation for local meetings
• Any payment in lieu of hospitality
• Any payment to doctors or groups of doctors for rental of rooms.
• Sporting activities
• Any costs related to accompanying persons

Finally, always remember that it is the impression which is all important - arrangements which appear unacceptable will be considered in breach of the Code, even if the actual arrangements are reasonable.

Sources of information

ABPI - Association of the British Pharmaceutical Industry, the industry trade association. www.abpi.org.uk

PMCPA - Prescription Medicines Code of Practice Authority, the independent body within the ABPI which administers the Code. See www.abpi.org.uk/links/assoc/pmcpa.asp - note a copy of the current Code is available to download in pdf format.

Code of Practice Review - published quarterly by the PMCPA and made widely and publicly available. It contains full details of all complaints and rulings, naming companies involved but not individuals. Copies of the latest issue are freely available by contacting the PMCPA directly.