What’s New in SAPI Code of Conduct?
In February 2021, the Singapore Association of Pharmaceutical Industries released a new version of his local code of conduct (3rd in twelve months). Main changes are related to chapter 12 (Communication to the Public) which has been greatly enhanced to add two subparts: Disease Awareness Programs (12.2) and Media Communications (12.3). Let’s have a quick look at the main additions.
Disease Awareness Programs
Disease awereness progams is a really interesting topic because highly country dependent. The IFPMA code (which is the base of any local association code of conduct) does not cover such type of activities. Here the statement from the global association in their Q&A: The IFPMA Code covers interactions with HCPs, medical institutions and patient organizations, and the promotion of pharmaceutical products. A public disease awareness campaign targeted at the public must not promote specific pharmaceutical products. Whilst not covered by the IFPMA Code, disease awareness campaigns must of course comply with local laws, regulations, and/or codes.
Most of local associations do not cover disease awerness programs in their code of conduct. Some of them, like the SFEE (Hellenic association of Pharmaceutical companies) shyly try to repeat the IFPMA principle (“public awareness campaigns/events may constitute disguised promotion”) while we find few codes of conduct going deeply into the details. When I have to define a disease awareness program, I like to refer to PIF code of ethics (Pharma Industry Finland): The objective of health awareness information is to encourage the consumer to maintain their own and their close ones’ good health, help them to recognize diseases, their symptoms and risk factors as well as guide the consumer to acquire additional information about the promotion of health and treatment of diseases.
Now, let’s take look on the Singaporean definition: A Disease Awareness Program is defined as information presented in a manner to educate and inform consumers on one or more types of diseases or medical conditions or treatments of such, for the purpose of raising public awareness and knowledge of such diseases, conditions or treatments.
It is interesting to note that the Singaporean definition is far less focused on the way to acquire additional information. Is it possible to mention product names? In theory yes (a range of treatments for example), but be careful, if it seems you encourage the public to seek information on a particular product, or seek prescription for a particular medicine, then it may be considered as an advertisement (especially if there is few medicinal treatments available). However, you can encourage a discussion with a physician. The emphasis of the educational information should be on the condition and its recognition rather than on the treatment options.
Encourage to reach a healthcare professional, yes… but not too much! The tone of the material or information must not be presented in a way that unnecessarily causes alarm or misunderstanding in the community, nor stimulate the demand for prescription of a specific product.
It reminds me Lynn Payer book about disease mongering (“Disease-Mongers: How Doctors, Drug Companies, and Insurers Are Making You Feel Sick.”). The Singaporean association is trying to avoid such groundless controversies. Again, if you look at the definition, the use of words is important: the goal of a disease awareness program is not to massively send people to physician offices.
Media Communications
The newly added subpart 12.3 brings some details on what can be done regarding: press release, advertorials / paid media, social media and website. Let’s start with press release as it is a simple case. These forms of communication are not considered as promotional and according to the Health Products (Advertisement of Specified Health Products) Regulations 2016, pre-approval from Health Sciences Authority is not required. The new version of SAPI code brings to attention the fact that press release must not be used not be used as a mechanism to promote a therapeutic product (don’t use promotional claim but only factual information) SAPI position on paid media is clear: General media articles concerning specific therapeutic products must not be initiated by companies. However, I want to underline a note: Companies should not attempt to encourage the publication of general media articles or their content with the aim of promoting their products. I understand that sponsorship of journalists to attend local and international Events may be a breach of this rule… keep it in mind.
Several articles are dedicated to Social Media. The main topic is, in my opinion, the compliance monitoring of social media. This is not a new practice but the code imposes a daily monitoring. Usergenerated posts on company-owned social media pages that do not comply with the above should be removed as soon as discovered (or at least within 1 business day) of posting. Moreover, it is also important to keep an eye on employees (not only external posts). Personal use of social media by a company employee that potentially identifies them as a company employee (e.g. LinkedIn), or that otherwise references their employer’s interests, may be perceived as advertising or promotion of a product. it’s the perfect time to remind that my analysis are based on personal researches and do not necessarily reflect the view of my company] And it’s a good transition with the last item on this new SAPI code: websites. Linking to Third Party Content if of course possible but under certain conditions (e.g. the linked content must comply with all applicable laws and regulations of Singapore).
If you share an article on Twitter or LinkedIn about a new drug indication released in US for example, you put your company at risk because firstly this post may be considered as promotional and secondly because this promotion may be off-label in your country.
My thoughts are that pharmaceutical companies should try to put more efforts to monitor public posts from their employees on social media even if it’s not that easy as data privacy is also frequently involved.
In conclusion, I find the new update of SAPI code of conduct very interesting: several of these new changes (on disease awareness program or media use) could be also transposed to some other countries. We can use it to shed light on real compliance risks regarding promotional and non-promotional activities.
