Select Committee on Health Written Evidence


APPENDIX 36

Memorandum by Lilly (PI 129)

RESPONSE TO THE MEMORANDUM BY THE UNIVERSITY OF STIRLING INSTITUTE FOR SOCIAL MARKETING ENTITLED "DEALING IN DRUGS: AN ANALYSIS OF THE PHARMACEUTICAL INDUSTRY'S MARKETING DOCUMENTS"

INTRODUCTION

  Lilly inputted its views on the House of Commons Health Select Committee inquiry into the influence of the pharmaceutical industry through the Association of the British Pharmaceutical Industry (ABPI). We received a request from the Health Select Committee ("the Committee") on the afternoon of Friday 10 December 2004, to which Lilly responded on Wednesday 22 December 2004. The Committee requested that we provided all marketing documentation related to two specific healthcare professional programmes associated with two disease areas in which Lilly has medicines. The Committee obtained information from five pharmaceutical companies in total, which was analysed by the University of Stirling Institute for Social Marketing (ISM), formerly the Centre for Social Marketing at Strathclyde University. A memorandum was made available to Lilly on Thursday 24 March 2005 (the "Stirling memorandum").

  While the Stirling memorandum was anonymised as to which companies' materials are discussed, Lilly was invited by the Committee to respond to the issues raised. We are grateful to the Committee for providing us with this opportunity to put our views on the record.

ETHICS

  Lilly's business is focused on the discovery and development of ethical branded medicines to enable people to live longer, fuller lives. Lilly takes its business ethics and adherence to the ABPI Code of Practice very seriously. We think it is gratuitous that the University of Stirling ISM has chosen to entitle their memorandum "Dealing In Drugs". In our view, this title misrepresents the type of company and industry we are, and what we are about—"Dealing In Drugs" has connotations of the recreational use of controlled substances, which is very definitely not the subject of the Committee's inquiry or their report.

  Given that the Stirling ISM was following the same process that the Committee asked them to adopt during their earlier obesity inquiry,[113] we note that on that occasion the title of the memorandum was balanced and objective, namely "Preliminary Analysis of Food Industry Advertising Documents".

DISCLOSURE

  Paragraph two of the introduction to the memorandum notes that each company was instructed to provide "all promotional and product support material for specific brands or programmes". As set out in Table 1 of the Stirling memorandum, Lilly was asked for all documents in relation to two specific healthcare professional programmes. Within this context, Lilly disclosed the documents that we held in relation to these, one of which has been endorsed as best practice in the Government's White Paper on public health, "Choosing Health"[114] and is being rolled out across Primary Care Trusts.

  We were surprised to see that the Stirling memorandum makes reference to "a very limited set of papers" considering that the five companies supplied 49 boxes of documents before Christmas 2004. Given this opinion, and the powers vested in the Committee, one wonders why this was not pursued in the three months after the initial request.

DISEASE AWARENESS

  It is not clear on what basis the Stirling ISM has concluded that disease awareness and public health campaigns are in breach of the ABPI Code of Practice.

EMOTION

  In relation to Figure 4 in the Stirling memorandum, Lilly is concerned that one diagram from one company is being used to portray "rational" and "emotional" as being of equal importance, and also of being representative of the approach taken to branding by the industry as a whole.

  Lilly believes that a section of one sentence in the Stirling memorandum may refer to the information Lilly provided about one of its programmes. We believe that there is no reference to the other programme.

  The Stirling memorandum criticises the use of emotive language to describe attributes of medicines, which it says runs counter to the requirement to provide factual, objective information. Examples given include "intimate", "relaxed" and "freedom". Lilly believes that this is a reference to our Cialis "36 Hours of Freedom" campaign to healthcare professionals and that the use of such language is entirely appropriate, legal and within the letter and spirit of the ABPI Code of Practice, given that they were used in the context of a Lilly/ICOS medicine licensed for the treatment of erectile dysfunction.

HEALTH SELECT COMMITTEE REPORT ON SEXUAL HEALTH

  Erectile dysfunction impacts the physical and emotional aspects of the lives of men and their partners. So while the claims made about the medicine are objective and accurate, they are presented in a context appropriate to the condition. The recently published "Recommended standards for sexual health services"[115] highlights the fact that people with sexual dysfunction may wait years before seeking professional help and notes: "It is important to create supportive environments that will enable early self-referral." Similarly, in relation to sex and relationships education, the Health Select Committee in its own recent report entitled "New developments in sexual health and HIV/AIDS policy"[116] stated that: "The biological facts are intended to be supplemented by, and interwoven with, a broader sex and relationships curriculum, which includes the social and emotional aspects of sexual relationships, through a dedicated framework for "Sex and Relationships Education" (SRE), which forms part of the Personal Social and Health Education (PSHE) curriculum." Lilly's activities in relation to erectile dysfunction are intended to provide healthcare professionals with an insight into the experience of the condition in order that they can deal with patients in a sensitive and appropriate way.

HEALTHCARE PROFESSIONALS OR THE GENERAL PUBLIC

  The Stirling memorandum does not make a clear distinction between promotion of medicines to healthcare professionals and to the general public. The Lilly example mentioned above relates to a specific communication directed solely to healthcare professionals.

INITIAL THOUGHTS OR APPROVED MATERIALS

  The Stirling memorandum reflects a lack of understanding of the ABPI Code of Practice. Lilly provided a whole range of documents: initial thoughts, work-in-progress, proposals submitted by our agencies, contracts and final, approved materials. The Stirling memorandum does not distinguish between these different types of document. All Lilly programmes are subject to internal review to ensure that they are consistent with Lilly's business ethics and the ABPI Code of Practice. There have been no complaints to the Pharmaceutical Medicines Code of Practice Authority (PMCPA) about either of the programmes on which the Committee requested information.

  It should also be noted that all member companies' promotional activities are subject to the ABPI Code of Practice, which is policed by the PMCPA and the Code of Practice Appeal Board.

ABPI CODE OF PRACTICE REVIEW

  Lilly notes that the Stirling memorandum analysis was conducted around themes taken from the ABPI Code of Practice, although the memorandum reflects a lack of understanding of the Code. It was established in 1958 and is one of the oldest in the medicines sector. It is updated regularly and periodically there are full reviews. The last major review was held in 1993. The principle of self-regulation is enshrined in EU legislation; it is well established in the UK: the Proprietary Association of Great Britain, the Press Complaints Commission and the Advertising Standards Authority regulate companies working in, respectively, over-the-counter-medicines, print and broadcast media.

  Self-regulation provides the flexibility to adapt to change and, from time to time, the pharmaceutical industry has a comprehensive review. The healthcare environment has changed significantly since the last major review. The political focus on creating a patient-centred NHS has led to widespread public debate on how the pharmaceutical industry and other stakeholders should communicate to patients.

  Under the chairmanship of Lilly's managing director in the UK, the ABPI embarked upon a major review of the Code of Practice almost a year ago. We anticipate a new Code of Practice with revised governance procedures will be published later this year.

April 2005






113   House of Commons Health Committee Report, "Obesity", Third Report 2003-04 Session, HC 23-III Ev 694, published on 14 June 2004. Back

114   Choosing Health: Making Healthier Choices Easier. Public health white paper, Department of Health November 2004. Back

115   Medical Foundation for AIDS and Sexual Health, endorsed by the Department of Health. Back

116   House of Commons Health Committee Report "New Developments in Sexual Health and HIV/AIDS Policy", Third Report 2004-05 Session, HC 252-1, section 80, page 27, published on 20 March 2005. Back


 
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Prepared 26 April 2005