| INTRODUCTION
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| 1. | The terms of reference for this inquiry have been stated by the Health Select Committee and this memorandum will only address those issues as they pertain to Paling Walters in the course of its work.
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| 2. | Paling Walters (PW) is a London-based advertising agency specialising in the advertising and promotion of medicines and healthcare products. Our immediate parent company is DAS Europe Limited and it, in turn, is owned by Omnicom Inc, which is based in New York.
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| 3. | The agency is retained by a number of pharmaceutical and consumer healthcare companies. PW also works with consumer companies on products that have a more diverse health offer (eg British Airways Travel Clinics, B&L contact lenses and British Meat). The agency works on both a UK and an International basis.
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| 4. | The agency was founded in 1980 and currently employs around 40 people.
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| OUR REMIT
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| 5. | The pharmaceutical companies use a number of external suppliers to aid them in their product marketing activities. These broadly fall into three sectors—
(1) Public Relations
(2) Medical Education
(3) Advertising and below-the-line (btl) promotion.
Many firms are involved in the first two areas; a small number of companies are engaged in all of these activities. PW only operates in the third business sector.
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| 6. | The provision of drug information and promotion. It is important to clarify and confirm the sort of work carried out by PW and the range of materials it creates. Our work on prescription medicines is aimed largely at primary and secondary care doctors, with a small percentage of our output aimed at other HCPs (eg pharmacists). Because of our target audience, the types of materials we create are invariably product orientated. This type of work is, of course, not aimed at patients. We have never promoted a prescription medicine to a patient. It is not allowed by law.
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| 7. | Almost exclusively these materials are in the form of:
(a) Press advertisements (paid for space and placed within the medical press)
(b) Mailings to the medical profession.
(c) Sales support materials for use by medical representatives face-to-face with GPs, hospital specialists etc, as part of the important process of bringing information to the medical profession.
The latter may take the form of brochures containing information such as clinical trial support for a product (in terms of efficacy, side-effect profile etc), dosage information and cost. Other items used by the medical representative, and produced by PW, may include exhibition panels, slide sets, product monographs, dosage information cards and brand reminders. We also produce, from time-to-time, materials for internal use within marketing and sales departments of pharmaceutical companies.
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| 8. | Professional and patient education. PW does not produce materials for either doctor or patient education, with one or two notable exceptions, which are outlined below.
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| 9. | Where we produce educational materials for doctors, such as A/V presentations and literature, these will invariably be branded and are part of the product's promotional package.
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| 10. | In terms of patient education, we only produce materials for the doctor to pass on to the patient post-diagnosis and after the patient has been given a prescription. These materials are given with the objective of aiding compliance with treatment and to give patients additional advice whilst on the treatment, to help them get the maximum benefit from their medicine and to ensure the treatment is taken safely. It is well accepted by doctors that patients are aided enormously by having written instruction to reinforce what has been told to them about treatment and dosage whilst in the surgery. It is also well documented that a large percentage of treatment courses are incorrectly taken by the patient and such advice is highly valuable.
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| 11. | Historically (1999), PW was involved in a campaign with the aim of communicating directly to patients about a medical disease (erectile dysfunction). This was a press campaign for The Men's Health Forum and The Impotence Association. There was no product association/mention in this work, although it was supported by an educational grant from Pfizer. Despite this and other subsequent campaigns, it is estimated that only 20% of sufferers with ED have sought any medical consultation.
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| OUR RESPONSIBILITY
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| 12. | Whilst pharmaceutical companies are at liberty to promote and sell their products to the medical profession, there are, of course, regulations in place to control this activity. We take a very responsible approach to the advertising and promotional work we produce in support of our clients' products.
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| 13. | Our advertising and promotional materials adhere to the rules laid down by the ABPI Code of Practice and the Health and Medicines Act/Medicines Advertising Act. All product claims made have to be substantiated and reflect the summary of product characteristics.
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| 14. | Within this context, it is important that PW copywriters and account managers are familiar with the details of the Code and how it affects their work. As a matter of protocol, all copywriters and account managers at our agency attend ABPI training courses on the Code. Other staff may also attend where there is additional value in them doing so. Staff are also sent on the course again from time to time as a refresher.
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| 15. | Our staff working in these areas, along with senior management, have medical, pharmacy or, at the very least, science degree qualifications. They need to be able to deal with science/medical-based materials. Staff in our clients' marketing and sales departments are similarly qualified.
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| 16. | Over and above our responsibility to convey information honestly and clearly, we also have a responsibility to our clients to produce materials that fall within the Code of Practice. Failure to do so results in punitive measures, intensive time investment from ourselves and our clients and damage to our overall relationship. The withdrawal and revision of materials results in a great deal of lost time and lost money from a marketing budget.
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| 17. | Breaches of the Code are taken very seriously indeed. There are strict internal legal and medical approval systems in pharmaceutical client companies, to which PW adheres. Promotional materials must not be issued by a company unless the final materials have been certified by two senior officials of the company, one of whom must be a registered medical practitioner. The other is often a pharmacist.
We have never witnessed anything other than a totally ethical attitude from our clients in terms of medical/legal approval.
The complaint procedure exists to ensure that there is an independent review and all breaches of the code are published and in the public domain. Through the ABPI Code, there is a potent mechanism for members to regulate each other. All breaches of the code are published and in the public domain.
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| THE AIM OF OUR WORK
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| 18. | Companies such as PW are employed by our clients to aid in the marketing of their products. We are engaged to help establish understanding by the medical profession of a product's values, its functionality and role in treatment management.
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| 19. | As such we have a responsibility to present our clients' products in the most positive way within its licence, given the data and the product profile. This is part of the necessary process by which clients compete within a commercial environment.
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| 20. | Importantly, when we promote products to the medical profession we are talking to a highly educated, intelligent and knowledgeable audience. They will place a product offer into the context of their pharmacological understanding and previous experience. The doctor is the final arbiter of what to prescribe and, indeed, whether to prescribe at all.
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| 21. | Whilst doctors need to understand the functional benefits of a product and gain experience of using/prescribing it, it is still possible to engage them through press advertising. However, advertising is a small component of the overall communication package. Much of the explanation and understanding doctors need to prescribe a product, or to extend its usage, is delivered via the literature, conferences, seminars, peer endorsement and contact with company representatives. This is where the details are discussed and the doctor has the opportunity to ask questions, gain clarification and disagree.
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| 22. | Representatives are frequently cited as one of the most important sources of information for doctors about new medicines, new indications, new data etc.
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| 23. | So from an advertising point of view the aim of our work is to:
(a) create awareness (eg at launch or in the early stages of a product's life);
(b) communicate a key message/offer;
(c) be part of the process to encourage trial (the doctor is then in a position to start formulating his own judgement); and
(d) act as a reminder for the product.
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| COMMENT |
| 24. | In the Health Select Committee's own words, "The pharmaceutical industry contributes substantially to the health of the nation and brings important benefits to the national economy." Therefore, the value of the industry itself does not seem to be the issue here. It would seem to be in everyone's interests that it continues to be both profitable and successful.
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| 25. | To return to the issue of the inquiry—the influence of the pharmaceutical industry. From the perspective of Paling Walters, a company that has worked with the pharmaceutical industry for almost 25 years, and has been proud to do so, it is our view that the industry does behave ethically in its dealings with the medical profession in the course of marketing its products. In the area of our remit, which is all we are qualified to comment on, checks and controls are in place to make sure that we maintain this ethical standpoint.
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