Clause 15 - Representatives

  • Clause 15 Representatives

    All provisions in the Code relating to the need for accuracy, balance, fairness, good taste etc apply equally to oral representations as well as to printed and electronic material. Representatives must not make claims or comparisons which are in any way inaccurate, misleading, disparaging, in poor taste etc, or which are outside the terms of the marketing authorization for the medicine or are inconsistent with the summary of product characteristics. Indications for which the medicine does not have a marketing authorization must not be promoted.

    Attention is drawn to the provisions of Clause 9.9 which prohibit the use of the telephone, text messages, email, telemessages and facsimile etc for promotional purposes, except with the prior permission of the recipient.

  • Clause 15 Contract Representatives

    Companies employing or using contract representatives are responsible for their conduct and must ensure that they comply with the provisions of this and all other relevant clauses in the Code, and in particular the training requirements under Clauses 15.1, 16.1 and 16.3.

15.1 Representatives must be given adequate training and have sufficient scientific knowledge to enable them to provide full and accurate information about the medicines which they promote.

15.2 Representatives must at all times maintain a high standard of ethical conduct in the discharge of their duties and must comply with all relevant requirements of the Code.

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AUTH/3180/4/19 - Respiratory nurse v AstraZeneca Breach: 9.1, 15.2 No breach: 9.1, 15.2 Applicable Code: 2016 Received: 04 April 2019 Completed: 29 October 2019 AUTH/3173/3/19 - Anonymous v Novo Nordisk Breach: 15.2 No breach: 1.11, 2, 9.1, 9.10, 12.1, 26.1 Applicable Code: 2016 Received: 18 March 2019 Completed: 14 October 2019 AUTH/3182/4/19 - Pharmacist v Astellas Breach: 15.2, 15.4 No breach: 9.1, 15.9 Applicable Code: 2016 Received: 10 April 2019 Completed: 02 October 2019 AUTH/2935/2/17 - Anonymous Ex-employee v Sunovion Promotion of Latuda Breach: 15.2, 15.9 No breach: 2, 9.1, 15.2, 15.9 Applicable Code: 2016 Received: 13 February 2017 Completed: 11 July 2019 AUTH/2831/4/16 - Voluntary admission by Celgene Meetings organised by representatives Breach: 2, 4.1, 4.10, 9.1, 14.1, 15.2, 18.1, 26.1 Applicable Code: 2016 Received: 01 April 2016 Completed: 18 April 2018 AUTH/2970/8/17 - Anonymous v Janssen Promotional email Breach: 9.1, 15.2 No breach: 2, 7.2, 7.4, 9.1, 12.1, 16.1 Applicable Code: 2016 Received: 10 August 2017 Completed: 01 February 2018 AUTH/2969/8/17 - Senior Practice Nurse v AstraZeneca Conduct of a representative Breach: 9.1, 15.2 No breach: 2, 7.2, 7.4, 8.1, 15.2, 15.4, 15.9 Applicable Code: 2016 Received: 03 August 2017 Completed: 26 January 2018 AUTH/2986/10/17 - Anonymous, non-contactable v Teva Conduct of a representative Breach: 15.2 No breach: 2, 9.1, 15.3, 15.5 Applicable Code: 2016 Received: 25 October 2017 Completed: 11 January 2018 AUTH/2954/4/17 - Health professional v AstraZeneca Conduct of a representative Breach: 7.2, 7.4, 9.1, 15.2, 15.4, 15.9 Applicable Code: 2016 Received: 18 April 2017 Completed: 12 July 2017 AUTH/2922/12/16 - Assistant Director Medicines Management v Meda Conduct of representative Breach: 7.2, 7.4, 15.2 No breach: 2, 15.2 Applicable Code: 2016 Received: 19 December 2016 Completed: 24 March 2017 AUTH/2917/12/16 - Anonymous, non-contactable v Janssen Conduct of a representative Breach: 15.2 No breach: 2, 9.1 Applicable Code: 2016 Received: 21 December 2016 Completed: 31 January 2017 AUTH/2828/3/16 - Clinical Nurse Specialist v Vifor Conduct of representatives Breach: 2, 7.2, 7.4, 7.9, 9.1, 9.9, 15.2, 15.9 No breach: 15.4 Applicable Code: 2016 Received: 21 March 2016 Completed: 07 December 2016 AUTH/2848/5/16 - Voluntary admission by Ferring Representative-facilitated letter Breach: 9.1, 12.1, 15.2 No breach: 2 Applicable Code: 2016 Received: 26 May 2016 Completed: 22 July 2016 AUTH/3548/7/21 - Complainant v Leo Breach: 2, 9.1 No breach: 2, 9.1, 15.2, 15.5 Applicable Code: 2019 Received: 14 December 2020 Completed: 13 January 2023 AUTH/3029/4/18 - Complainant v GW Pharmaceuticals Arrangements for a meeting, alleged promotion of Epidiolex and unapproved slides No breach: 2, 3.1, 9.1, 14.1, 15.2, 22.1 Applicable Code: 2016 Received: 05 April 2018 Completed: 21 December 2018 AUTH/3026/3/18 - Anonymous Employee v Sanofi Promotion of Toujeo and Lantus Breach: 9.1, 15.9 No breach: 2, 9.1, 3.2, 15.2, 15.9 Applicable Code: 2016 Received: 16 March 2018 Completed: 19 December 2018 AUTH/3113/11/18 - Ex-employee v Novartis Medical Representatives Examination No breach: 2, 15.2, 16.3 Applicable Code: 2016 Received: 06 November 2018 Completed: 14 December 2018 AUTH/3014/1/18 - Anonymous, non-contactable health professional v GW Pharmaceuticals Promotion of Epidiolex Breach: 2, 3.1, 9.1 No breach: 2, 3.1, 9.1, 7.2, 15.2 Applicable Code: 2016 Received: 22 February 2018 Completed: 22 November 2018 AUTH/3061/8/18 - Health professional v Ferring Conduct of a representative No breach: 9.1, 15.2, 15.4, 15.9 Applicable Code: 2016 Received: 21 August 2018 Completed: 26 October 2018 AUTH/3024/3/18 - Anonymous , non-contactable Hospital Consultant v GW Pharmaceuticals Alleged promotion of Epidiolex No breach: 2, 9.1, 3.1, 15.2 Applicable Code: 2016 Received: 12 March 2018 Completed: 18 October 2018 AUTH/3028/3/18 - Ex-Employee v AbbVie Production of a poster and use of case studies Breach: 9.1, 9.10, 14.1 No breach: 2, 15.2 Applicable Code: 2016 Received: 23 March 2018 Completed: 17 October 2018 AUTH/3057/8/18 - Clinical Commissioning Group employee v Novo Nordisk Conduct of a representative No breach: 2, 3.2, 9.1, 15.2 Applicable Code: 2016 Received: 15 August 2018 Completed: 16 October 2018 AUTH/2997/12/17 - Anonymous health professional v AbbVie Promotion of Synagis Breach: 9.1, 14.1 No breach: 2, 7.2, 7.4, 9.1, 15.2 Applicable Code: 2016 Received: 18 December 2017 Completed: 17 July 2018 AUTH/3008/1/18 - Teva v Pharmasure Provision of a chocolate hamper Breach: 2, 9.1, 18.1 No breach: 15.2 Applicable Code: 2016 Received: 22 December 2017 Completed: 22 March 2018 AUTH/2981/9/17 - Member of the public v ViiV Use of an iPad in public No breach: 2, 9.1, 15.2, 26.1 Applicable Code: 2016 Received: 26 September 2017 Completed: 23 November 2017 AUTH/2973/8/17 - Anonymous v Bayer Conduct of a representative No breach: 15.2 Applicable Code: 2016 Received: 31 August 2017 Completed: 28 September 2017 AUTH/2943/3/17 - Ex-employee of a service provider v Bayer Conduct of an employee Breach: 2, 9.1, 15.9 No breach: 3.2, 8.2, 9.1, 15.2 Applicable Code: 2016 Received: 08 March 2017 Completed: 21 July 2017 AUTH/2946/3/17 - Anonymous Consultant Oncologist v Merck Serono Conduct of representative No breach: 7.1, 7.5, 9.1, 11.2, 15.2, 15.4, 15.9 Applicable Code: 2016 Received: 20 February 2017 Completed: 28 June 2017 AUTH/2937/2/17 - Anonymous, non contactable v Merck Serono Conduct of representative No breach: 15.2, 15.9 Applicable Code: 2016 Received: 16 February 2017 Completed: 17 March 2017 AUTH/2887/11/16 - Anonymous health professional v AstraZeneca Meeting attendees and speaker reference to Saxagliptin Breach: 9.1 No breach: 9.1, 11.1, 15.2, 22.1, 2 Applicable Code: 2016 Received: 14 November 2016 Completed: 10 February 2017 AUTH/2919/12/16 - Anonymous, non-contactable v Merck Sharp & Dohme Conduct of representative No breach: 2, 9.1, 15.2 Applicable Code: 2016 Received: 14 December 2016 Completed: 20 January 2017 AUTH/2852/6/16 - Ex-employee v Grunenthal Medical science liaisons’ working practices No breach: 2, 3.2, 9.1, 11.1, 12.1, 15.2, 15.4, 15.9 Applicable Code: 2016 Received: 20 June 2016 Completed: 14 September 2016

15.3 Representatives must not employ any inducement or subterfuge to gain an interview. No fee should be paid or offered for the grant of an interview.

  • Clause 15.3 Hospitality and Payments for Meetings

    Attention is drawn to the requirements of Clauses 18 and 22 which prohibit the provision of any financial inducement for the purposes of sales promotion and require that any hospitality provided is secondary to the purpose of a meeting, is not out of proportion to the occasion and does not extend beyond members of the health professions or other relevant decision makers.

    Meetings organised for groups of doctors, other health professionals and/or other relevant decision makers which are wholly or mainly of a social or sporting nature are unacceptable.

    Representatives organising meetings are permitted to provide appropriate hospitality and/or to meet any reasonable, actual costs which may have been incurred. For example, if the refreshments have been organised and paid for by a medical practice the cost may be reimbursed as long as it is reasonable in relation to what was provided and the refreshments themselves were appropriate for the occasion.

    Donations in lieu of hospitality are unacceptable as they are inducements for the purpose of holding a meeting. If hospitality is not required at a meeting there is no obligation or right to provide some benefit of an equivalent value.

  • Clause 15.3 Donations to Charities

    Donations to charities in return for representatives gaining interviews are prohibited under Clause 15.3.

  • Clause 15.3 Items Delivered by Representatives

    Reply paid cards which refer to representatives delivering items to health professionals or other relevant decision makers should explain that there is no obligation to grant the representative an interview when the items are delivered. This is to avoid the impression that there is such an obligation, which would be contrary to Clause 15.3 which prohibits the use of any inducement or subterfuge to gain an interview.

  • Clause 15.3 Health Professionals’ Codes of Conduct

    The General Medical Council, the General Pharmaceutical Council and the Code of the Nursing & Midwifery Council, set out requirements for doctors, pharmacists, pharmacy technicians, nurses and midwives. Further details are given in the supplementary information to Clauses 18.1 and 22.

15.4 Representatives must ensure that the frequency, timing and duration of calls on health professionals and other relevant decision makers in hospitals and NHS and other organisations, together with the manner in which they are made, do not cause inconvenience. The wishes of individuals on whom representatives wish to call and the arrangements in force at any particular establishment, must be observed.

  • Clause 15.4 Frequency and Manner of Calls on Doctors and Other Prescribers

    The number of calls made on a doctor or other prescriber and the intervals between successive visits are relevant to the determination of frequency.

    Companies should arrange that intervals between visits do not cause inconvenience. The number of calls made on a doctor or other prescriber by a representative each year should not normally exceed three on average. This does not include the following which may be additional to those three visits:

    • attendance at group meetings, including audio-visual presentations and the like
    • a visit which is requested by a doctor or other prescriber or a call which is made in order to respond to a specific enquiry
    • a visit to follow up a report of an adverse reaction.

    Representatives must always endeavour to treat prescribers’ time with respect and give them no cause to believe that their time might have been wasted. If for any unavoidable reasons, an appointment cannot be kept, the longest possible notice must be given.

    When briefing representatives companies should distinguish clearly between expected call rates and expected contact rates. Contacts include those at group meetings, visits requested by doctors or other prescribers, visits in response to specific enquiries and visits to follow up adverse reaction reports. Targets must be realistic and not such that representatives breach the Code in order to meet them.

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AUTH/3182/4/19 - Pharmacist v Astellas Breach: 15.2, 15.4 No breach: 9.1, 15.9 Applicable Code: 2016 Received: 10 April 2019 Completed: 02 October 2019 AUTH/2954/4/17 - Health professional v AstraZeneca Conduct of a representative Breach: 7.2, 7.4, 9.1, 15.2, 15.4, 15.9 Applicable Code: 2016 Received: 18 April 2017 Completed: 12 July 2017 AUTH/2867/8/16 - Anonymous, non contactable ex-employee v UCB Conduct of representatives Breach: 9.1, 15.4, 15.9 No breach: 2 Applicable Code: 2016 Received: 09 August 2016 Completed: 11 October 2016 AUTH/2857/7/16 - Anonymous, non-contactable v Daiichi-Sankyo Promotional activities and call rates Breach: 15.4, 15.9 No breach: 2, 3.1, 3.2, 4.1, 9.1, 14.1 Applicable Code: 2016 Received: 25 July 2016 Completed: 30 September 2016 AUTH/2823/2/16 - Anonymous, contactable v Grunenthal Conduct of representatives Breach: 2, 9.1, 15.4, 15.9, 23.1, 29 No breach: 2, 9.1, 18.1 Applicable Code: 2016 Received: 23 February 2016 Completed: 16 August 2016 AUTH/3105/10/18- Pharmacy team leader v Eli Lilly No breach: 2, 9.1, 15.4 Applicable Code: 2016 Received: 08 October 2018 Completed: 25 February 2019 AUTH/3061/8/18 - Health professional v Ferring Conduct of a representative No breach: 9.1, 15.2, 15.4, 15.9 Applicable Code: 2016 Received: 21 August 2018 Completed: 26 October 2018 AUTH/3030/4/18 - Anonymous employee v UCB Activities under the Code No breach: 2, 9.1, 14.1, 15.3, 15.4, 15.9 Applicable Code: 2016 Received: 06 April 2018 Completed: 03 July 2018 AUTH/2969/8/17 - Senior Practice Nurse v AstraZeneca Conduct of a representative Breach: 9.1, 15.2 No breach: 2, 7.2, 7.4, 8.1, 15.2, 15.4, 15.9 Applicable Code: 2016 Received: 03 August 2017 Completed: 26 January 2018 AUTH/2962/7/17 - Sales representative v Pierre Fabre Call rates and certification of meetings Breach: 2, 9.1, 14.1, 15.9 No breach: 9.1, 14.1, 15.4, 15.9, 16.3 Applicable Code: 2016 Received: 31 July 2017 Completed: 05 January 2018 AUTH/2955/4/17 - Anonymous Employee v Boehringer Ingelheim Call rates No breach: 2, 9.1, 15.4, 15.9 Applicable Code: 2016 Received: 25 April 2017 Completed: 01 August 2017 AUTH/2947/3/17 - Anonymous v Sanofi Representatives’ call rates Breach: 9.1, 15.9 No breach: 15.4, 15.1, 15.9 Applicable Code: 2016 Received: 22 March 2017 Completed: 14 July 2017 AUTH/2946/3/17 - Anonymous Consultant Oncologist v Merck Serono Conduct of representative No breach: 7.1, 7.5, 9.1, 11.2, 15.2, 15.4, 15.9 Applicable Code: 2016 Received: 20 February 2017 Completed: 28 June 2017 AUTH/2828/3/16 - Clinical Nurse Specialist v Vifor Conduct of representatives Breach: 2, 7.2, 7.4, 7.9, 9.1, 9.9, 15.2, 15.9 No breach: 15.4 Applicable Code: 2016 Received: 21 March 2016 Completed: 07 December 2016 AUTH/2852/6/16 - Ex-employee v Grunenthal Medical science liaisons’ working practices No breach: 2, 3.2, 9.1, 11.1, 12.1, 15.2, 15.4, 15.9 Applicable Code: 2016 Received: 20 June 2016 Completed: 14 September 2016 AUTH/2844/5/16 - Voluntary admission by Amdipharm Mercury Email sent by a representative Breach: 7.2, 7.4, 9.1, 14.1 No breach: 15.4 Applicable Code: 2016 Received: 11 May 2016 Completed: 07 July 2016

15.5 In an interview, or when seeking an appointment for one, representatives must at the outset take reasonable steps to ensure that they do not mislead as to their identity or that of the company they represent.

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15.6 Representatives must transmit forthwith to the scientific service referred to in Clause 25.1 any information which they receive in relation to the use of the medicines which they promote, particularly reports of adverse reactions.

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15.7 Representatives must be paid a fixed basic salary and any addition proportional to sales of medicines must not constitute an undue proportion of their remuneration.

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15.8 Representatives must provide, or have available to provide if requested, a copy of the summary of product characteristics for each medicine which they are to promote.

  • Clause 15.8 Provision of Summary of Product Characteristics

    The requirement to provide a copy of the summary of product characteristics can be met by the provision of an electronic copy if the recipient agrees.

    If discussion on a medicine is initiated by the person or persons on whom a representative calls, the representative is not obliged to have available the information on that medicine referred to in this clause.

15.9 Companies must prepare detailed briefing material for medical representatives on the technical aspects of each medicine which they will promote. A copy of such material must be made available to the Medicines and Healthcare products Regulatory Agency and the Prescription Medicines Code of Practice Authority on request. Briefing material must comply with the relevant requirements of the Code and, in particular, is subject to the certification requirements of Clause 14.

Briefing material must not advocate, either directly or indirectly, any course of action which would be likely to lead to a breach of the Code.

  • Clause 15.9 Briefing Material

    The detailed briefing material referred to in this clause consists of both the training material used to instruct medical representatives about a medicine and the instructions given to them as to how the product should be promoted.

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AUTH/2935/2/17 - Anonymous Ex-employee v Sunovion Promotion of Latuda Breach: 15.2, 15.9 No breach: 2, 9.1, 15.2, 15.9 Applicable Code: 2016 Received: 13 February 2017 Completed: 11 July 2019 AUTH/3161/2/19 - Employee v Leo Pharma Breach: 15.9 No breach: 2, 9.1, 9.9, 14.1, 15.6, 15.9, 19.1, 19.2 Applicable Code: 2016 Received: 19 February 2019 Completed: 18 June 2019 AUTH/3026/3/18 - Anonymous Employee v Sanofi Promotion of Toujeo and Lantus Breach: 9.1, 15.9 No breach: 2, 9.1, 3.2, 15.2, 15.9 Applicable Code: 2016 Received: 16 March 2018 Completed: 19 December 2018 AUTH/3017/2/18 - Anonymous contactable v Celgene Certification and approval of material for meetings Breach: 9.1, 14.1, 15.9 No breach: 2, 9.1, 14.1 Applicable Code: 2016 Received: 31 January 2018 Completed: 02 August 2018 AUTH/3012/1/18 - Voluntary admission by Pierre Fabre Failure to certify material Breach: 2, 3.1, 7.2, 7.4, 9.1, 14.1, 15.9 No breach: 4.8 Applicable Code: 2016 Received: 19 January 2018 Completed: 21 March 2018 AUTH/2962/7/17 - Sales representative v Pierre Fabre Call rates and certification of meetings Breach: 2, 9.1, 14.1, 15.9 No breach: 9.1, 14.1, 15.4, 15.9, 16.3 Applicable Code: 2016 Received: 31 July 2017 Completed: 05 January 2018 AUTH/2951/4/17 - Consultant physician v Sanofi Promotion of Toujeo Breach: 7.2, 7.4, 9.1, 15.9 No breach: 7.2 Applicable Code: 2016 Received: 06 April 2017 Completed: 12 September 2017 AUTH/2943/3/17 - Ex-employee of a service provider v Bayer Conduct of an employee Breach: 2, 9.1, 15.9 No breach: 3.2, 8.2, 9.1, 15.2 Applicable Code: 2016 Received: 08 March 2017 Completed: 21 July 2017 AUTH/2947/3/17 - Anonymous v Sanofi Representatives’ call rates Breach: 9.1, 15.9 No breach: 15.4, 15.1, 15.9 Applicable Code: 2016 Received: 22 March 2017 Completed: 14 July 2017 AUTH/2954/4/17 - Health professional v AstraZeneca Conduct of a representative Breach: 7.2, 7.4, 9.1, 15.2, 15.4, 15.9 Applicable Code: 2016 Received: 18 April 2017 Completed: 12 July 2017 AUTH/2928/1/17 and AUTH/2929/1/17 - Anonymous v Pfizer and Novartis Pharmacovigilance compliance, promotion of an unlicensed indication and breach of undertaking Breach: 2, 3.2, 9.1, 7.2, 15.9, 29 No breach: 2, 3.2, 7.2, 9.1, 15.6, 15.9, 16.2, 25.1, 29 Applicable Code: 2016 Received: 04 January 2017 Completed: 06 July 2017 AUTH/2920/12/16 - Anonymous, non-contactable ex-employee v UCB Promotion of Naloxone Minijet Breach: 9.1, 15.9 No breach: 2, 3.2 Applicable Code: 2016 Received: 20 December 2016 Completed: 27 March 2017 AUTH/2867/8/16 - Anonymous, non contactable ex-employee v UCB Conduct of representatives Breach: 9.1, 15.4, 15.9 No breach: 2 Applicable Code: 2016 Received: 09 August 2016 Completed: 11 October 2016 AUTH/2857/7/16 - Anonymous, non-contactable v Daiichi-Sankyo Promotional activities and call rates Breach: 15.4, 15.9 No breach: 2, 3.1, 3.2, 4.1, 9.1, 14.1 Applicable Code: 2016 Received: 25 July 2016 Completed: 30 September 2016 AUTH/2840/4/16 and AUTH/2847/5/16 - Anonymous, non contactable v Novartis and Pfizer Promotion of Ultibro Breezhaler and Seebri Breezhaler Breach: 3.2, 7.2, 9.1, 15.9 No breach: 2, 3.2, 7.2, 9.1, 15.9 Applicable Code: 2016 Received: 25 April 2016 Completed: 16 September 2016 AUTH/2823/2/16 - Anonymous, contactable v Grunenthal Conduct of representatives Breach: 2, 9.1, 15.4, 15.9, 23.1, 29 No breach: 2, 9.1, 18.1 Applicable Code: 2016 Received: 23 February 2016 Completed: 16 August 2016 AUTH/3182/4/19 - Pharmacist v Astellas Breach: 15.2, 15.4 No breach: 9.1, 15.9 Applicable Code: 2016 Received: 10 April 2019 Completed: 02 October 2019 AUTH/3158/2/19 - Employee v Servier No breach: 2, 7.2, 7.4, 7.9, 9.1, 12.1, 15.9, 23.1, 25.1 Applicable Code: 2016 Received: 05 February 2019 Completed: 30 May 2019 AUTH/3056/8/18 - Ex-representative vs GlaxoSmithKline – Conduct of GlaxoSmithKline Breach: 3.2, 7.2, 9.1 No breach: 2, 3.2, 7.2, 9.1, 15.9, 18.1, 19.1, 19.2, 23.1 Applicable Code: 2016 Received: 31 July 2018 Completed: 12 March 2019 AUTH/3061/8/18 - Health professional v Ferring Conduct of a representative No breach: 9.1, 15.2, 15.4, 15.9 Applicable Code: 2016 Received: 21 August 2018 Completed: 26 October 2018 AUTH/3030/4/18 - Anonymous employee v UCB Activities under the Code No breach: 2, 9.1, 14.1, 15.3, 15.4, 15.9 Applicable Code: 2016 Received: 06 April 2018 Completed: 03 July 2018 AUTH/2969/8/17 - Senior Practice Nurse v AstraZeneca Conduct of a representative Breach: 9.1, 15.2 No breach: 2, 7.2, 7.4, 8.1, 15.2, 15.4, 15.9 Applicable Code: 2016 Received: 03 August 2017 Completed: 26 January 2018 AUTH/2956/5/17 - Ex-employee v Napp Flutiform promotional practices No breach: 2, 7.2, 7.4, 9.1, 15.9, 19.1, 19.2 Applicable Code: 2016 Received: 08 May 2017 Completed: 29 August 2017 AUTH/2955/4/17 - Anonymous Employee v Boehringer Ingelheim Call rates No breach: 2, 9.1, 15.4, 15.9 Applicable Code: 2016 Received: 25 April 2017 Completed: 01 August 2017 AUTH/2946/3/17 - Anonymous Consultant Oncologist v Merck Serono Conduct of representative No breach: 7.1, 7.5, 9.1, 11.2, 15.2, 15.4, 15.9 Applicable Code: 2016 Received: 20 February 2017 Completed: 28 June 2017 AUTH/2937/2/17 - Anonymous, non contactable v Merck Serono Conduct of representative No breach: 15.2, 15.9 Applicable Code: 2016 Received: 16 February 2017 Completed: 17 March 2017 AUTH/2852/6/16 - Ex-employee v Grunenthal Medical science liaisons’ working practices No breach: 2, 3.2, 9.1, 11.1, 12.1, 15.2, 15.4, 15.9 Applicable Code: 2016 Received: 20 June 2016 Completed: 14 September 2016

15.10 Companies are responsible for the activities of their representatives if these are within the scope of their employment even if they are acting contrary to the instructions which they have been given.