How to make sure your meetings programme is ABPI compliant

This is where the ABPI 2006 code of practice comes into its own, specifically clause 19 which deals with the arrangement and holding of HCP meetings within the Pharmaceutical industry. The key requirement being that the main purpose of the meeting should be its content and any hospitality offered during these meetings should not only be secondary but in fact no more than basic subsistence.

How can we work out what would and would not be acceptable? In answering this question, you would need to consider all aspects of the meeting from the venue, timings, hospitality, content (including speakers) and all associated materials ie handouts, stand material and invitations and equally as important, the costs. All of these elements factor in how the end product, the meeting, will be perceived. This is how it would be deemed acceptable or not, the overall impression given from combining all of these elements. Therefore, one of the requirements of the code is that all Pharmaceutical companies have a specific policy dealing with meetings and hospitality. This must be adhered to otherwise companies can find themselves in breach of the code which can ultimately lead to heavy sanctions against the offending company.

What sort of meetings are acceptable? In simple terms, educational meetings. This however does not rule out promotional meetings as these can be just as educational as non-promotional meetings. Either way, the educational content of the meeting must be the primary purpose of the meeting.

To achieve the right balance between educational content and hospitality the following must be considered. Timings- Does the length of the meeting justify the hospitality offered? For example, a meeting lasting one hour in the afternoon does not warrant an elaborate 3 course dinner and overnight accommodation, however if the meeting commenced at 12 noon and ran till 6pm and extended until the following morning, then this level of hospitality could be justified.

Costs/Quality- Is the cost and quality of the hospitality in accordance with the level of the meeting? For example, a good quality venue with 3 course dinner could be booked for a meeting featuring an international speaker however would not be justifiable for a local GP speaker meeting as this would be more appropriately hosted in a conference centre.

Arrangements- Have the arrangements been made to be suit the educational content of the meeting? For example, a talk over dinner suggests that the educational content comes secondary to the food, whereas a short meeting with just simple refreshments would indicate that the education is why people are attending.

Advertising Emphasis- Does the advertisement of the meeting ‘sell' the content or the venue/hospitality? For example, if the meeting is billed on the invitations as a ‘Gala Dinner' or being held at a ‘Luxury and Renowned Venue' this would be seen as luring the attendees on the hospitality or the quality of the venue. The meeting must be advertised with the educational content being its primary ‘selling' point.

Venue- Is the venue appropriate to the purpose of the meeting? The meeting content should be planned first and only then a venue should be sourced to fit in with that content. Never should a venue be hired and the meeting content be edited to fit to that specific venue. The venue must be professional and offer privacy for the duration of the educational content of the meeting. Nightclubs and Casinos are a big no-no.

Sporting venues and Spas should be avoided unless there really is no alternative venue to host the meeting. Any sporting venue that is used should have no fixtures immediately before, during or after the meeting. Location of the venue is also important. For example, it would not be acceptable to hold a local GP speaker meeting from the midlands in central Scotland as this would mean unnecessary travelling, accommodation, expense and would be perceived as the venue being the main attraction for the meeting allowing the attendees a mini-break on the back of the meeting.

Activities- Which activities are acceptable during the meeting? Any activity offered must be professional. Activities can only be offered if they relate to the main educational purpose of the meeting. Any activity which is mainly for entertainment value should not be included. For example, a round of golf, Spa treatments, wine tasting. These activities are unprofessional and therefore unacceptable in accordance with the code.

Materials- Which materials can be used? All meetings should ideally be documented by at least an invitation or a letter confirming arrangements. All materials used must comply with the relevant sections of the code which also includes materials produced by third parties as the Pharmaceutical companies have overall compliance responsibility. Sponsorship must be clearly stated on all relating material whether the meeting is promotional or not. All materials used must show that the meeting is in accordance to the code. For example, invitations/stands must not give the wrong impression of the meeting content.

There are many factors which could potentially lead to a breach of the code in booking a meeting for HCP's. Some Pharmaceutical companies are seeking help in this area by using venue sourcing companies who have been certified by an industry consultant and have in-depth knowledge of what is and not acceptable under the ABPI 2006 code of compliance. This is proving to be of great use to them as although it does not remove their ultimate responsibility, it acts as a further safe guard in the need to comply.

In summary, perception is key. Put yourself in the position of an outside observer, how would it look to you?