The global voice for consumers

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The global voice for consumers
La voix des Consommateurs à travers le monde
La voz global para la defensa de los consumidores
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A consumer perspective on the regulation of
pharmaceutical marketing Pharmaceutical
regulatory and compliance congress and best
practice forum

• 29 May 2008
• Justin Macmullan
• Head of Campaigns
• Consumers International

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About Consumers International

• Consumers International (CI) is the only
  independent global campaigning voice for
  consumers.
• Founded in 1960
• 220 member organizations in 115 countries
• Act as a global watchdog on the behaviour of
  international corporations

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CI research on pharmaceutical marketing

• Branding the cure (2006)
• Marketing codes of companies operating in Europe
• Revealed twenty companies had breached the ABPI
  guidelines 972 times in a four year period.
• Drugs, doctors and dinners (2007)
• Marketing to doctors in emerging economies
• Suggested that irresponsible marketing practices
  in these emerging markets is widespread .

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CIs approach to pharmaceutical marketing

• Support processes that will ensure doctors and
  consumers have access to independent, accurate,
  timely and comparable information about
  medicines.
• Independent bodies and publications that provide
  such information receive the support they need.
• Effective regulation to manage the conflict of
  interest that exists when a profit based company
  is asked to provide information about their own
  product

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The role of voluntary standards

• Positive role
• To raise standards above the mandatory level
• To improve conduct in countries where there is
  limited capacity to implement or enforce
  mandatory regulations

• Negative role
• Where is is used to argue against or pre-empt the
  need for mandatory standards
• CSR as PR
• A plethora of different codes and standards

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Main concerns with drug marketing

• 1. Adverts
• Studies and examples highlight misleading
  information and omissions
• Situation appears to be worse in emerging
  economies
• Lack of clear procedures for pre -approval of
  adverts.

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Main concerns with drug marketing

• 2. Marketing representatives
• Difficult to monitor
• Gift giving
• A ban on all gifts to doctors. Clarity, training,
  hotlines, effective action against offenders.

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Main concerns with drug marketing

• 3. Lack of transparency on financial
  relationships
• Conflict of interest in the funding of CME,
  patient groups and disease awareness campaigns
• An industry wide international commitment to
  transparency is an obvious first step

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Main concerns with drug marketing

• 4. Clarity on contact with consumers
• Disease awareness campaigns
• Online activities websites and chat rooms
• Clarify policies in codes
• Clear and explicit guidelines for staff

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How can codes of conduct be improved?

• Transparency commitments should be clear,
  accessible and readily available.
• Comprehensive commitments should cover all
  aspects of marketing.
• Effective enforcement

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Conclusion

• CSR is not an alternative to mandatory
  legislation consumers are sceptical of
  companies commitment when they oppose regulation
  and only make commitments under the threat of
  legislation.
• Clarity and transparency on commitments,
  processes and complaints should be a first step.
• Given the nature of prescription medicines CI
  feels we can accept nothing less than the highest
  possible level of consumer protection.