AUTH/2370/11/10: Anonymous employee v Sanofi-Aventis (alleged excessive hospitality at overseas meetings) – No breach | PMCPA Case

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Key facts

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Case number	AUTH/2370/11/10
Parties	Anonymous employee v Sanofi-Aventis
Issue	Alleged excessive hospitality (including alcohol) at overseas meetings
Meetings	IBCC (Paris, Jan 2009); ASCO GU (San Francisco, Mar 2010)
Applicable Code year	2008
Complaint received	22 November 2010
Case completed	7 February 2011
Clauses considered	Clauses 2, 9.1 and 19.1
Decision	No breach of the Code (no breach of Clauses 2, 9.1, 19.1)
Panel observations	Extremely concerned about limited records and inability to provide requested detail; could only calculate averages; company could not guarantee Code requirements were met, but evidence was insufficient to uphold a breach
Hospitality figures (examples)	Paris: dinners ~€60.13/€60.70 (~£55) per head; drinks over two days for 50 delegates and 11 employees cost £1568.41 (avg £25.71); San Francisco: $50 hotel voucher first evening; dinners $82.85 and $62.12 per head (incl half bottle of wine)
Appeal	No appeal

Reviewed by Dr Anzal Qurbain (FFPM) — ABPI Final Signatory

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An anonymous Sanofi-Aventis employee alleged the company provided excessive hospitality to delegates at two overseas meetings: IBCC in Paris (Jan 2009) and ASCO GU in San Francisco (Mar 2010).
Paris allegation: employees “plied customers with large amounts of alcohol” and individual entertainment bills ranged from £200 to over £500.
San Francisco allegation: a named UK consultant oncologist was “wined and dined excessively”; one occasion allegedly over $100 per head for entertainment only; alleged this led to inappropriate behaviour in a bar.
The complainant provided no identity or contact details, so the Authority could not seek further information.
Sanofi-Aventis relied on internal records/expense claims and did not interview staff who attended.
Paris records showed pre-arranged dinners (~£55 per head) and additional bar/third-party entertainment claims by four representatives; documentation lacked detail on attendees, timing (before/after dinner), and what was consumed.
San Francisco records showed a $50 hotel voucher for the first evening and two organised dinners ($82.85 and $62.12 per head) with half bottle of wine; no employee expense claims for third-party entertainment.

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No breach of the Code was ruled.
No breach of Clause 19.1 (hospitality) for either meeting.
No breach of Clauses 2 and 9.1.
The Panel expressed strong concern about the lack of detail/records for the Paris meeting and the company’s inability to provide requested additional information, describing this as potentially “extremely poor practice”, but still ruled no breach based on the limited evidence available.

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