Chiesi: internal compliance update slides not the examined version at sales meeting (AUTH/2784/7/15)

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Key facts

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Case number	AUTH/2784/7/15
Complainant	Anonymous, non-contactable ex-employee
Company	Chiesi
Issue	Alleged failure to certify materials (unapproved slides used during a compliance update at a sales meeting)
Meeting/date	Internal Chiesi UK sales meeting; 21 May 2015
Complaint received	27 July 2015
Case completed	20 August 2015
Applicable Code year	2015
Clauses considered	2, 9.1, 14.1, 15.9
Panel decision	No breach of the Code
Appeal	No appeal
Additional sanctions	None stated

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

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An anonymous, non-contactable ex-employee complained about a presentation delivered at a Chiesi UK sales conference/meeting (May 2015).
The complainant alleged the presenter realised mid-session that the projected slides were not the approved version, told the audience they were significantly different, and continued with the unapproved deck.
Chiesi said the session (“Compliance Update – Succeeding the Right Way”) was a 30-minute update on Code/compliance topics (eg PMCPA audits, transparency reporting dates, 2016 Code), not product training or selling instructions.
Chiesi acknowledged a miscommunication meant the examined version of slides was not sent to the AV production company; the original version was used.
Chiesi stated the two slide versions did not differ in any meaningful way and provided a document setting out differences.
Chiesi documented and disseminated a written process to prevent incorrect slide versions being used at internal meetings.

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No breach of the Code.
The Panel found the presentation was a general Code/compliance update and did not directly or indirectly refer to a medicine or how it should be promoted.
Therefore, the Code did not require the material to be certified as product briefing material.
The Panel also found the slides used were closely similar to those intended; while unfortunate, this did not amount to a failure to maintain high standards.

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