Letter from AstraZeneca to the Clerk of
the Committee (PI 131)
RESPONSE TO THE UNIVERSITY OF STIRLING INSTITUTE
OF SOCIAL MARKETING'S REPORT
Thank you for sending us a copy of The Institute
of Social Marketing's report "An Analysis of the Pharmaceutical
Industry's Marketing Documents" and for the opportunity to
respond. We are concerned with the premises upon which the report
appears to have been based which leads us to have reservations
about its conclusions:
the report appears to assert thatin
principlethe use of commercial marketing techniques in
the promotion of prescription pharmaceuticals to the NHS is an
inappropriate, undesirable activity and contrary to existing legislation
and the ABPI Code of Practice; and
further, the report does not appear
to distinguish in its allegations between internal documents detailing
strategy and market analysis, which are not subject to the Code,
and external market activities, which must adhere to the Code.
A substantial majority of the material that
we submitted to the Health Select Committee was internal documentation
of analysis, discussion and planning.
Not only do we operate within the ABPI Code
of Practice, but we pride ourselves on our ethical marketing and
business practices. We strive to produce appropriate communications
and materials all of which go through a rigorous internal approval
process. During the two year period for the products considered
in the report, activities which resulted in complaints were dealt
with under the Code in the appropriate way and actions taken where
breaches were ruled (Ref: Code of Practice Review, published by
the PMCPA). Whilst the documents provided by us to the Committee
must, as agreed, remain confidential, we wish to ensure that the
Committee has recourse to the PMCPA. Should they wish to make
a specific complaint regarding external activities, we would be
pleased to discuss any such example.
We undertake our marketing activities to the
highest professional standards. We strongly believe that the marketing
and communications regarding our medicines play a crucial role
in their appropriate use and the wider provision of healthcare
in the UK. We work hard to understand the experiences of patients
who may receive our medicines, and the complexities of the diseases
from which they suffer. Firstly, this ensures that our communications
to healthcare professionals are informed by insight into the patients
they will be seeing and treating. Secondly, this supports appropriate
communications to healthcare professionals about our medicines
and sometimes supports a conscious decision to promote healthcare
awareness to patients and patient groups.
The news media play an increasingly influential
role in the public awareness of disease, healthcare and medicines.
However newspaper articles do not always result in the public
being appropriately and accurately informed. AstraZeneca is committed
to providing accurate information to meet the needs of healthcare
professionals, members of the public and journalists. There must
be an accurate understanding of the risks and benefits of medicines.
We believe that our activities encourage the appropriate use of
medicines and correct misleading information.
Medical treatment decisions are made based on
both the rational and emotional motivations of both healthcare
professional and patient. It is frequently necessary to take these
factors into account in our communications, and in this way to
facilitate optimal outcomes for patients.
As an industry, the medicines that we provide
are central to the health and wellbeing of UK patients. The reputation
and trust of the industry are a vital part of this. As a leading
UK pharmaceutical company AstraZeneca takes these issues very
seriously. Should the Committee have remaining concerns that are
not satisfied by this memorandum, nor by recourse to the PMCPA,
we would want to continue this important discussion promptly with
We would like to emphasise that a balanced consideration
of the marketing of medicines in the UK should be based on a firm
knowledge and grasp of the current practice of scientific innovation,
medical practice, commercial marketing and ABPI Code of Practice.
In our view, the current report represents an overly narrow perspective
on these areas.
We hope that these comments are a constructive
contribution to an important review by the Health Select Committee.
18 March 2005