1. La voix des Consommateurs à travers le monde
The global voice for consumers
La voz global para la defensa de los consumidores

2. Consumers International
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

3. 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’

4. 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 .

5. CI’s 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

6. 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

7. 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.

8. 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.

9. 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

10. 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

11. 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

12. 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.