Access to Medicine Index 3 rd International Conference for Improving the Use of Medicines Poster 599 Tuesday 15 th November 2011

Access to Medicine Index A New Approach Based on a multi-stakeholder engagement process, the Index attempts to define the role and establish best practices of companies’ behaviour regarding access to medicine and to rank company policies & practices. Facilitate and inform dialogue among the stakeholders on access issues. Function as a learning tool for the industry through establishing and describing best practices Motivate competition among the pharmaceutical companies – through the ranking process – along the 4 strategic dimensions Serve as a decision support tool for other stakeholders who interact and collaborate with pharmaceutical companies

Access to Medicine Index 2010 Methods Framework structure: 107 indicators are used to assess the companies Structured along 2 axes of analysis Scope & study poulation: 20 largest pharmaceutical companies Data from the 2008 & 2009 Financial Year’s Policies & activities accross 88 countries & 33 diseases.

Access to Medicine Index 2010 Study Objectives This poster presents a descriptive sub-analysis looking at seven of the indicators used in Index The indicators were selected as those assessing the ‘marketing and promotion (M&P)’ policies and practices of the companies assessed. The analysis is split into two parts: 1.Companies positions and responses to legal and regulatory frameworks governing ethical M&P practices (4 indicators) 2.What are companies activities in this area (3 indicators)

Access to Medicine Index 2010 The Marketing & Promotion Indicators…

Access to Medicine Index 2010 Results: M&P Regulation Currently 100% (20) of companies analysed, commit to ethical marketing as an organisation (IFPMA, WHO) and as individual employees (CoC). As the codes are ‘global’ in reach they form the basis of ensuring ethical marketing and promotion in IC’s. For Index 2010, 35% (7) of companies did not demonstrate evidence of the existence of procedures and mechanisms to monitor (and ensure) compliance with company marketing standards in IC-markets.

Access to Medicine Index 2010 Results: Compliance and assurance For the 70% (14) of companies who did disclose the assurance mechanisms used to ensure ethical marketing in IC’s. Typical ones include: Detailed policies Employee training Compliance officers / committees Contractually binding or performance-linked Whistle-blower mechanisms (compliance hotlines) Audit mechanisms.

Currently 40% (8) of companies analysed, commit to demand ethical marketing conduct from these third parties, consistent with their own internal standards. Of these 50% (4) currently ensure this in practice by either making the commitment contractual (binding) or by providing evidence of supporting compliance mechanisms. Of the 12 companies who do not currently make such a commitment, 42% have general ethical guidelines or recommendations that are non- binding or the companies reaction to breaches is not defined. Access to Medicine Index 2010 Results: M&P through 3 rd parties

Access to Medicine Index 2010 Results: Marketing & Promotion Activities At present not one company analysed, discloses or reports the nature of the marketing and promotion activities or resource support (including direct payments to individuals) made in the IC’s.

During the period of analysis no major litigation in the IC’s was found regarding marketing and promotion activities across the sector. WHO guidelines = proposes enforcement a National level IFPMA = collects code breaches, but they not presently, publicly, available. Company disclosure of its litigations is variable across the sector: Some companies disclose all code breaches, fines and litigations related to marketing practices also in IC’s Some companies disclose settled litigations, those with a negative ruling or incidents in western markets The location, nature and date of an incident frequently not disclosed. Access to Medicine Index 2010 Results: Code Breaches and Litigations

Access to Medicine Index 2010 Conclusions: Current Situation Ethical marketing of pharmaceutical companies are governed by voluntary self-regulation and enforcement is internally or locally dependent. Given the important role companies play in provision of medical information in IC’s: the dearth of disclosure remains a stakeholder concern. Majority of companies provide evidence of internal compliance and assurance mechanisms in IC’s. Our findings reveal that compliance with, and coverage of, these systems is less clear and robust: In some (frequently, low income) IC’s With respect to ‘out-sourced’ activities (conducted through 3 rd -parties) Index welcomes the early indications, from a number of companies, that they will soon start to disclose

Access to Medicine Index 2010 Conclusions: Policy Implications By establishing metrics to measure companies, the Index aims to: Build a deeper and broader understanding of the current situation and practice in this area & how behaviour changes overtime Be a driver for greater transparency Facilitate policy development and stakeholder engagement w/industry. Evidence gaps remain around industry’s role in this area, the impact of these activities and the causal relationships (marketing & behaviour). WHO and HAI have been instrumental in providing guidance and highlighting the particular areas of concern around company-driven activities which will serve to focus efforts in this area.

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