Decision

December 2017: Conduct of Kyowa Kirin Representatives at Meeting

Published 22 February 2018

MHRA received an anonymous complaint via the Prescription Medicines Code of Practice Authority (PMCPA) that raised concerns about the conduct of two Kyowa Kirin representatives at the Ynys Mon Medical Society meeting of 12 September 2017 at the Oriel Ynys Mon in Llangefni. It is alleged that one of the representatives who were promoting a variety of products at the Kyowa Kirin stand also discussed a project and services available from the company during the promotion of these products.

Under Clause 19.1 of the ABPI Code of Practice, the provision of goods and services must not be linked in any way to the promotion of medicinal products. This is designed to ensure that they do not constitute an inducement to prescribe, supply, administer, recommend, buy or sell any medicine.

The MHRA investigated this case under regulation 300 of the Human Medicines Regulations 2012 which prohibits the provision of inducements to prescribe or supply medicines. Kyowa Kirin carried out a full internal investigation and informed the MHRA in a detailed response that the two representatives were part of a promotional team that operated separately from the company’s healthcare project team.

Kyowa Kirin stated that the representatives had no knowledge of any proposed project or services on offer. When approached by two healthcare professionals wishing to discuss the proposed Kyowa Kirin health project at the stand, the representatives informed them that they were not able to discuss the matter and redirected them to the appropriate contact.

On the basis of this evidence, MHRA did not uphold the complaint.