Clauses 9.1 and 9.2 Suitability and Taste
The special nature of medicines and the professional audience to which the material is directed require that the standards set for the promotion of medicines are higher than those which might be acceptable for general commodity advertising.
It follows therefore that certain types, styles and methods of promotion, even where they might be acceptable for the promotion of products other than medicines, are unacceptable. These include:
Clause 9.5 MHRA Drug Safety Update
Where factual safety information given in promotional material is based on advice in the MHRA Drug Safety Update, the information can be referenced to that publication.
Clause 9.7 Extremes of Format, Size or Cost
Particular care needs to be taken in this regard in the first six months following the launch of a medicine to avoid criticism of the industry.
Clause 9.8 Reply Paid Cards
Reply paid cards which are intended to be returned to companies through the post and which relate to a prescription only medicine should not bear both the name of the medicine and information as to its usage but may bear one or the other.
Clause 9.9 Unsubscribing to emails
Where permission to use emails for promotional purposes has been given by a recipient, each email sent should inform the recipient as to how to unsubscribe to them.
Clause 9.9 Responding to emails
An enquiry received by email can be responded to by email without specific permission, consent to do so being implied in such circumstances. There is no need to inform recipients as to how to unsubscribe to an email response to an enquiry.
Clause 9.10 Declaration of Sponsorship
The declaration of sponsorship must be sufficiently prominent to ensure that readers of sponsored material are aware of it at the outset.
The wording of the declaration must be unambiguous so that readers will immediately understand the extent of the company’s involvement and influence over the material. This is particularly important when companies are involved in the production of material which is circulated by an otherwise wholly independent party, such as supplements to health professional journals.
Clause 9.10 Market Research
Where market research is carried out by an agency on behalf of a pharmaceutical company, the agency must reveal the name of its client to the Prescription Medicines Code of Practice Authority when the Authority requests it to do so. When commissioning market research, a company must take steps to ensure that its identity would be so made known to the Authority should a request for that information be made.