Hospira: UK pharmacists taken to Croatia for ‘advisory board’/site visit—Panel found overseas promotional meeting, inappropriate venue and poor governance (AUTH/2820/2/16)

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Key facts

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Case number	AUTH/2820/2/16
Parties	Media/PMCPA Director v Hospira
Issue	Arrangements for an overseas meeting (Zagreb manufacturing site visit + advisory board)
Trigger	Daily Telegraph article (17 February 2016) alleging trips abroad at top hotels; Hospira named
Complaint received	17 February 2016
Case completed	5 July 2016
Applicable Code	2016 (Clauses referenced from 2015 Code; 2016 Constitution and Procedure applied)
HCP attendees	Five UK pharmacists (two from the same NHS trust)
Company/agency attendees	Three Hospira staff + one communications agency employee
Location	Zagreb, Croatia (plus overnight at Heathrow due to flights)
Hospitality cost	Average total hospitality ~£449.40 per person plus economy airfares
Educational content	~7 hours total (including ~3.5 hours advisory board); manufacturing site day had ~3.5 hours educational content
Key compliance gaps	No consultancy contracts; advisory board not bona fide; insufficient UK certification/recertification; inappropriate venue; no clear and cogent reason for overseas location
Breach clauses	2, 9.1, 18.1, 22.1, 23.1
No breach clauses	22.2
Sanctions	Undertaking received; Advertisement
Appeal	No appeal

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

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What happened

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A Daily Telegraph article (17 Feb 2016) criticised pharma payments to senior NHS staff and named Hospira for hosting UK officials at a Zagreb hotel described as five-star with spa/casino.
The PMCPA took the matter up as a complaint under the Code (Paragraph 6.1 of the Constitution and Procedure).
Hospira said the trip combined (1) a visit to its Zagreb biologics manufacturing site and (2) an advisory board about biosimilars (including Inflectra).
Attendees were five UK pharmacists (two from the same NHS trust), with three Hospira staff plus one communications agency employee also attending.
Hospira initially invited 17 potential delegates aiming for 10–12, largely to maximise numbers able to visit the manufacturing site.
No honoraria were paid, but travel, accommodation and meals were funded (via an agency and reimbursed by Hospira). Average total hospitality was ~£449.40 per person plus economy airfares.
Delegates stayed three nights (including an overnight at Heathrow due to flight timings) for ~7 hours total educational content (including ~3.5 hours for the advisory board).
Hospira did not put written contracts in place for the advisory board participants (an internal misunderstanding that contracts were unnecessary if no fee was paid).
Although the meeting/materials were approved at a European level, the UK-specific reassessment and certification did not occur for most materials and the overall meeting/venue decision.
The Zagreb hotel was described by Hospira materials as “the finest hotel in Zagreb” and formerly part of “Leading Hotels in the World”; it was ~45 minutes from the manufacturing site.

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Outcome

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The Panel ruled the arrangements were not those of a genuine advisory board and that the event amounted to an unacceptable overseas promotional meeting for UK health professionals.
Breach rulings: Clauses 2, 9.1, 18.1, 22.1 and 23.1.
No breach: Clause 22.2 (meals were within Croatian Code limits: HRK500 (~£52); dinners were £24.14 and £37.18 per head).
No appeal.
In exceptional circumstances, the Panel decided not to report Hospira to the Code of Practice Appeal Board under Paragraph 8.2.
The Panel requested Hospira be reminded of disclosure requirements set out in the Code.

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