Roche voluntary admission: promotional employee had not taken ABPI Medical Representatives Examination (AUTH/2609/6/13)

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Key facts

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Case number	AUTH/2609/6/13
Company	Roche Products Limited
Case type	Voluntary admission (treated as a complaint under Paragraph 5.6 of the Constitution and Procedure)
Issue	Failure of a promotional employee to take/pass the ABPI Medical Representatives Examination
Employee role	Relations manager (field-based; reported to a head office manager)
Role start date	December 2010
Status at time noted by Panel	In May 2013 had not yet taken or passed the ABPI Medical Representatives Examination
Applicable Code year	2012
Complaint received	07 June 2013
Case completed	11 July 2013
Breach clauses	Clause 9.1; Clause 16.3
No breach clauses	Clause 2
Sanctions	Undertaking received; Additional sanctions: Not stated
Appeal	No appeal
Immediate corrective action stated	Employee instructed to cease promotional activity and moved to a non-promotional role; ABPI status of other relations managers checked

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

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Roche Products Limited voluntarily advised the PMCPA that one promotional employee (a “relations manager”) had not taken the ABPI Medical Representatives Examination.
The employee moved from a non-promotional role into the promotional relations manager role in December 2010 and, as of May 2013, had not taken or passed the exam.
The issue was discovered during Roche’s investigation to respond to another matter (Case AUTH/2603/5/13), where the Authority asked whether staff who paid for hospitality at a UK congress had passed the ABPI exam.
The relations manager role was field-based but unusually reported to a head office manager; Roche said the normal field-manager check of ABPI qualification did not occur due to this reporting line.
Roche immediately instructed the employee to cease all promotional activity and transitioned the employee to a non-promotional role.
Roche checked the ABPI exam status of all other relations managers and confirmed all others had successfully completed the exam.
Roche stated it would revise the relations manager job description and revise its representative training SOP to ensure internal transfers into promotional roles were checked with the same rigour as new hires.

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Breach of Clause 16.3 was ruled (representatives must pass the appropriate ABPI representatives examination within the required timeframe).
Breach of Clause 9.1 was ruled (failure to maintain high standards due to lack of a process to check exam status for internal transfers).
No breach of Clause 2 was ruled (Panel did not consider “particular censure” warranted in the circumstances).
No appeal.

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