Grünenthal breached Clause 15.4 after sales email blurred “interactions” with call vs contact rates

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Key facts

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Case number	AUTH/2652/11/13
Complainant	Anonymous, non-contactable employee
Company	Grünenthal
Issue	Failure to distinguish between call rates and contact rates in a sales-force email referring to “interactions” and daily activity expectations
Material	Email to UK sales force about CRM (Advance) interaction entry and “role activity standard” (e.g., 2+ target interactions/day; 5–7 total/day)
Applicable Code year	2012
Complaint received	08 November 2013
Case completed	07 January 2014
Breach clauses	Clause 15.4
Outcome	Breach found (narrow ground alleged)
Appeal	No appeal
Sanctions	Undertaking received; additional sanctions: Not stated

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

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An anonymous, non-contactable employee complained about an email from a senior employee to the UK sales force about daily entry of customer “interactions” into the CRM system (Advance).
The email stated expectations such as “2+ target interactions per day” and “5-7 total interactions per day” as a “role activity standard”, and referenced historic averages (above 7 interactions/day in 2012).
The complainant alleged the email failed to reflect the Code requirement to distinguish clearly between expected call rates and expected contact rates, because it only referred to “interactions”.
Grünenthal argued the email was administrative (about CRM completeness), not a call-rate briefing; and that “interactions” included 1:1 calls and meeting contacts, with no incentivised call/contact targets.
The Panel considered the email went beyond administration and effectively briefed representatives on expected activity levels, so it needed to comply with Clause 15.4 and its supplementary information.

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Breach found: Clause 15.4 (on the narrow ground alleged—insufficient clarity distinguishing call rates vs contact rates when briefing representatives).
No appeal.
Undertaking received.

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