Sanofi Genzyme: patient organisation guests at BIA gala dinners ruled inappropriate hospitality (AUTH/2821/2/16)

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Key facts

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Case number	AUTH/2821/2/16
Company	Sanofi Genzyme
Issue	Inappropriate hospitality for patient organisation members at BIA gala dinners; subsistence likely exceeded £75 (2015)
Event(s)	Biotech Industry Association (BIA) gala dinners (2014 and 2015)
Complaint received	18 February 2016
Case completed	11 April 2016
Applicable Code year (PMCPA listing)	2014
Breaches (PMCPA listing)	Clause 19.1 and Clause 19.2
2014 attendance (as described)	3 employees + 7 patient organisation guests; ticket £425 + VAT; accommodation at least one attendee (£160) and travel paid for at least one attendee
2015 attendance (as described)	2 patient organisation guests (invited verbally last-minute) plus other attendees; ticket £450 + VAT; accommodation £149.99 each for 2 guests; travel paid for 2 attendees
Sanctions	Undertaking received
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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Sanofi Genzyme voluntarily admitted inviting members of patient organisations to the Biotech Industry Association (BIA) gala dinners in 2014 and 2015 and providing hospitality where there was no scientific/promotional meeting, congress or training.
The PMCPA Director treated the voluntary admission as a complaint (Paragraph 5.6 of the Constitution and Procedure).
The Panel considered the BIA gala dinner an important networking event but not one with clear educational content where hospitality was secondary; the venue was prestigious and the hospitality significant.
2014: Sanofi Genzyme took a table; 3 employees attended with 7 patient organisation guests. Ticket cost stated as £425 + VAT; accommodation (£160) and travel were paid for at least one attendee (submission implied accommodation for all patient organisation attendees).
2015: Sanofi Genzyme took a table of 10; attendees included company employees plus guests including 2 patient organisation members (invited last-minute verbally, outside the electronic approval system). Ticket cost stated as £450 + VAT; accommodation provided for the two patient organisation attendees at £149.99 each; travel was also paid for two attendees.
Sanofi Genzyme attended the January 2016 gala dinner but did not invite any patient organisation members and decided to stop attending the gala dinner going forward.
Sanofi Genzyme provided a new SOP requiring all activities with patient organisations to be reviewed for compliance with the Code.

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Outcome

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Breach ruled for inviting patient organisations to the 2014 gala dinner (under the Second 2012 Code as amended).
Breach ruled for inviting patient organisations to the 2015 gala dinner (under the 2014 Code).
Breach ruled for subsistence likely exceeding the £75 limit for the 2015 event (under the 2014 Code).
The Panel noted concerns that 2015 invitations were verbal and did not go through approval systems; it highlighted that Clause 14.3 (2014 Code) required material related to working with patient organisations to be certified, and asked that its concerns be drawn to the company’s attention (no ruling under Clause 14.3 in this case report).
No rulings were made on Clauses 9.1 and 2 because they were not cited for the company to consider.

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Key facts

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