Select Committee on Health Written Evidence


Supplementary memorandum by GlaxoSmithKline (PI 132)


  GlaxoSmithKline (GSK) supports the need for regulation of the advertising and promotion of medicines, and specifically supports self regulation under the PMCPA Code of Practice. Regrettably, the company has, on occasions, been found to be in breach of the Code of Practice. These breaches are taken extremely seriously by the company and are always reviewed to ensure that similar breaches do not recur. If these breaches involve the action of an individual acting contrary to instruction, disciplinary action is always taken.

  In respect of the analysis of industry marketing practices undertaken for the Committee by the Institute for Social Marketing, we are unable to respond in great detail given the generality of the analysis and conclusions.

  We are disappointed to note, however, that the authors have chosen to entitle their analysis "Dealing in Drugs". This is somewhat ironic, since they are particularly critical of anything they perceive to be the use of emotive language in industry's promotional efforts. Our view as to the appropriateness of the title can best be summed up by quoting from the ISM's authors themselves; that is to say, "words like `objective' and `balanced' sit uncomfortably with . . . techniques . . . which play on patently subjective feelings and emotions", as this title appears to be intended to do.

  The Institute for Social Marketing's analysis is based on a large amount of information supplied to the Committee by GSK and by other companies. We do not immediately recognise the instances portrayed in the 15-page analysis as representing material supplied by GSK. Our preliminary analysis, however, suggests that some if not all of the analysis is based on a fundamental misapprehension of the nature of the Code and the legal framework that underpins it.

  Marketing, and other forms of promotion, exist to increase sales of products beyond the level that would occur if such activity did not take place. Companies would not otherwise engage in this activity. This is entirely legitimate. Neither the Code of Practice, nor the Medicines Act, nor the EU Directive on the Advertising and Promotion of Medicines prohibits this activity; rather they regulate it. However, the Institute for Social Marketing analysis appears to be based in part on an assumption that any activity designed to increase the level of sales of a company's products is, by definition, in breach of the Code. This assumption is simply incorrect. The ISM analysis also seems rooted in a philosophical standpoint that anything done by a company with the intention of encouraging the use of its medicines and which benefits that company is inherently wrong. We disagree entirely with such a standpoint. ISM's report is based on muddled thinking and an incorrect appreciation of the regulatory framework, and this therefore calls into question the reliability of the report's conclusions.

  Carried out responsibly, promoting the use of medicines serves not merely the interests of pharmaceutical companies, but is also of benefit to patients and to the UK. Modern medicines can improve the quality and length of life and allow major diseases to be treated without the need for in-patient hospital care. They can allow patients to remain economically active, when they would otherwise be dependent on carers or social services. Medicines are therefore part of the solution, not part of the problem for the NHS. Indeed, the problem in the UK is not the widespread over-use of new medicines, but rather the opposite. Research clearly shows that UK uptake of new medicines is about one quarter of that in the average of comparable countries one year after launch, and remains low thereafter. Put simply, compared to many of their European or American counterparts, UK patients get poorer or later access to life-saving or life-enhancing new drugs.

  The Institute for Social Marketing's report also seems to have assumed that the analyses companies use to inform their marketing campaigns are the same as the execution of those campaigns. Implementation of campaigns is subject to the Code of Practice and the Medicines Act, but the thinking that informs those campaigns, as outlined in some of the documents provided to the Committee, may well not be.

  The Institute for Social Marketing's analysis also appears to find it blameworthy that industry would want to use public relations to counter criticism of medicines in the media—criticism that can often be factually incorrect and therefore unnecessarily distressing to patients who rely on those treatments. It would be astonishing if a company did not to seek to defend itself or its products from unwarranted attacks, and we believe such activity to be entirely legitimate.

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Prepared 26 April 2005