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All things Pharma

The science of compliance

Part four: The exhibition table

Steve Gray answers your questions about compliance with the ABHI Code of Business Practice and other industry codes that govern commercial activity.

This article is based on a query recently received from one of our readers. The names and other specifics have been changed. Please keep sending in your questions!

Dear Steve:

As a local representative for MK Continence Devices, I have been asked to sponsor an educational meeting organised by a local group of healthcare professionals. The meeting is in a syndicate room in a local hotel. We are exhibiting our products on a promotional table – which, due to the layout of the venue, has to be in the same room as the presentation screen used for the educational content of the meeting.

What protocol should I follow regarding the promotional display table? Should I leave the room and cover the table from view during the educational meeting, then unveil it during refreshment breaks in the meeting?

Steve says:

Let’s consider the options and implications. The primary guiding principle here is that of separation, but what does that mean in this context?

MK Continence Devices is allowed to promote its products by buying advertising space – in this instance, the advertising space takes the form of an exhibition stand. Consider what expectations would apply if the advertising space were a page in a medical journal: would the company have to find a way of covering the advertising page while the reader was reading the educational text? Of course not, that’s just silly. So there is no reason to apply any different rules for advertising at a meeting – under normal circumstances. There is no requirement in the ABHI (or any Code) to hide the exhibition stand as a matter of course.

So when could the exhibition stand be a problem? Let’s consider its potential location. It is most likely to be at the back of the room (behind the audience as they face the speaker). Or it might be at the side of the room, but not directly in the line of vision for the vast majority of the audience. In both cases, the only time the audience will look at the stand is when they are meant to, i.e. during the breaks.

However, if the stand is at the front of the room next to the screen, I can see how that might be a cause for concern. The audience will be able to see the promotional display constantly during the presentation, and any references that are made to company products will naturally result in eyes being drawn to the display stand. That is distracting for the audience and unfair to the speaker. It also subtly changes the perceived relationship between the product and the meeting: MK Continence Devices could be seen as having a much greater influence on the meeting and the content of the talk than is actually the case. Common sense and courtesy suggest that the most appropriate thing might be to cover the stand during the talk – or not to put it in that place to start with.

The other principle in the ABHI Code to consider is that of transparency. As with all meetings, MK Continence Devices needs to consider the expectations of the audience. A company should never be present at an event unless the audience knows before they are arrive that the event is sponsored by industry.

All that remains is the acceptance of the organizers: you must respect their wishes. Assuming that the event organiser is happy for the stand to be in the room, then I foresee no issues. However, you must abide by their wishes.

In this example, we have used a room in a local hotel. The venue is irrelevant: it is the purpose of your presence at the meeting that determines what is acceptable here, not the venue. It is also appropriate to consider that individual companies may apply different rules: ABHI defines the minimum standards that apply to its members, but a company can choose to apply stricter standards.

Steve Gray is an experienced compliance specialist and Managing Director of Compliance Hub Ltd, an accredited provider of training services to the ABHI. For details, see www.compliance-hub.com.

Do you have a compliance query for Steve Gray? If so, e-mail your question to us at joel.lane@medtechbusiness.co.uk. Your anonymity is guaranteed.
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