Grünenthal: complaint about frequency/volume of Palexia promotional mailings (AUTH/2513/6/12) – no breach | PMCPA Case

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Key facts

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Case number	AUTH/2513/6/12
Complainant	Anonymous employee (non-contactable)
Company	Grünenthal Ltd
Medicine	Palexia (tapentadol)
Issue	Alleged excessive frequency/volume of promotional mailings (including implication of mailing after every call)
Applicable Code year	2012
Clauses considered	9.1 and 11.2
Decision	No breach
Complaint received	13 June 2012
Case completed	26 June 2012
Appeal	No appeal

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

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An anonymous, non-contactable employee complained about the frequency and volume of Palexia (tapentadol) promotional mailings to health professionals.
The allegation was that after every call on a target customer, Grünenthal sent a brand reminder mailer and dosage card—potentially resulting in more than eight mailings per year and/or several in a short period.
The complainant provided an internal marketing newsletter stating that a call would be picked up in the CRM system and within 7 days a letter and dosage card would be mailed to the customer.
The PMCPA asked Grünenthal to respond under Clauses 9.1 and 11.2.
Grünenthal said the contact-activated brand reminder mailing was designed to be sent only once per GP during its active period (April–December 2012), with duplication prevented via mailing-provider checks against prior recipients.
Grünenthal provided mailing history and planning controls, stating that from February 2011 to June 2012 the maximum any single GP could have received was four Palexia mailings; any single secondary care health professional two.

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No breach of the Code was ruled.
No breach of Clause 11.2 (restraint on frequency/volume of promotional material).
No breach of Clause 9.1 (high standards).
The Panel noted the newsletter could have been more clearly stated because it implied a mailing after every call, but the evidence supported Grünenthal’s process and volumes.

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