5. Scientific Exchanges

5.1Promotional Activities1
Promotional activities refer to member employee to stakeholder interactions that involve dissemination of product information to promote the sale of a drug. Refer to Definition of Advertising under Definitions section above. Any HCP to HCP interaction is considered to be a learning program, refer to Section 9.

5.1.1General Principles

5.1.1.1

Members must provide full and factual information on products, without misrepresentation or exaggeration. Statements must be accurate and complete. They should not be misleading, either directly or by implication.

5.1.1.2

With respect to their promotional activities Members agree to comply with all applicable provisions of Health Canada (HC) regulations2, the Code of Advertising Acceptance of the Pharmaceutical Advertising Advisory Board (PAAB)3 and the Code of Advertising Standards of Advertising Standards Canada (ASC). A breach of the PAAB and/or ASC Codes or Health Canada Guidelines4 may be deemed by the IPRC to be a breach of this Code.

[[2]]Health Canada’s Food & Drugs Act & Regulations
www.hc‐sc.gc.ca/fn-­an/legislation/acts-­lois/act-­loi_reg-­eng.php[[2]]

[[3]]Pharmaceutical Advertising Advisory Board
www.paab.ca[[3]]

[[4]]Advertising Standards Canada
www.adstandards.com[[4]]

5.1.1.3

Occasional reasonable meals/refreshments may be offered in connection with promotional presentations by Member employees to Health Care Professionals and other Stakeholders attending the presentation.5

[[5]]For promotional activities, reasonable meals / refreshments can only be provided to clinic / medical staff who are appropriate to the primary business focus of the presentation or meeting. The amount should be reasonable, relative to the number of participants.[[5]]

5.1.1.4

Members will not promote prescription medicines that are not approved in Canada or unauthorized uses of approved prescription medicines. Promotion of unauthorized prescription medicines and uses is prohibited irrespective of an employee’s function within the Member company.

5.1.1.5

Members’ promotional activities must never involve pro-active or solicited discussion of off-label indications, uses, dosages, or populations and must be consistent with the approved prescribing information in the product monograph.

5.1.2Signing of Promotional Materials by Medical/Scientific Personnel

5.1.2.1

Member’s promotional materials are communications whose purpose is to advertise a Members’ product(s). Such communications must not be signed by Member employees who work in medical, regulatory or medical/scientific information services. Member employees who work in those areas may, however, sign the following types of communications, including without limitation:6

a. Responses to medical/scientific information requested by a Health Care Professional;
b. Essential, new medical safety information which has not been requested (for example, cover letters for new product monographs and letters that advise on product safety, the withdrawal of a product, new warnings, precautions and contraindications).

[[6]]We understand that members of the Medical function review promotional materials internally, before submission to a regulatory body. However, those materials should never be signed by Medical when distributed or transmitted to Health Care Professionals. For example: a piece (e.g. direct mail) that is promotional should not be signed by Medical.[[6]]

5.2Non-Promotional Activities

5.2.1General Principles

5.2.1.1

The prohibition against off-label promotion is not intended to restrict the non-promotional exchange of scientific information or the right of the scientific community and the public to be fully informed concerning scientific and medical progress.

5.2.1.2

Occasional reasonable meals/refreshments may be offered in connection with non-promotional presentations by Member employees to Health Care Professionals and other Stakeholders attending the presentation.7

[[7]]For non‐promotional activities, reasonable meals / refreshments can only be provided to clinic / medical staff who are appropriate to the primary business focus of the presentation or meeting. The amount of meals / refreshments provided should be reasonable, relative to the number of participants.[[7]]

5.2.2Standards

5.2.2.1

Requests for information on unauthorized product or uses will be referred to the Members medical department.

5.2.2.2

Legitimate circumstances exist for Members’ qualified scientific and medical personnel to communicate scientific information about their prescription medicines for optimal patient care in response to specific unsolicited queries and in the context of research activities and scientific exchange.

5.2.2.2.2

Communication of off-label scientific information must be distinct and separate from promotional activities.

5.2.2.2.1

Responses to queries concerning unauthorized products or uses must disclose clearly that the information concerns unauthorized products or usage and must also clearly state the approved product indication.

5.2.3New Product Information

5.2.3.1

Members should take all reasonable measures to ensure that Health Care Professionals are informed in a timely manner with respect to all new product information and ensure that this product information (such as the product monograph or excerpts from it) is sent to drug information centres, poison control centres, faculties of medicine, national medical associations and pharmacies across Canada, before the product is launched.8

[[8]]This refers to national medical and pharmacy associations.[[8]]