AUTH/2955/4/17: Anonymous employee complaint about call/contact rates at Boehringer Ingelheim (No breach)

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Key facts

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Case number	AUTH/2955/4/17
Parties	Anonymous non-contactable employee v Boehringer Ingelheim
Issue	Call/contact rates, target list sizes, alleged pressure to overcall; alleged bullying/fear culture and reps being “managed out”
Complaint received	25 April 2017
Case completed	1 August 2017
Applicable Code year	2016
Clauses considered	2, 9.1, 15.4, 15.9
Decision	No breach of Clauses 2, 9.1, 15.4 and 15.9
Appeal	No appeal
Notable Panel observations	Concerns about inconsistent/unclear “calls vs contacts” messaging and missing Clause 15.4 references in key documents; company to be advised of concerns

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

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An anonymous, non-contactable employee complained about representatives’ “call rates” and small target lists, alleging this created pressure to overcall and that some reps were “managed out” for missing targets.
The complainant cited examples including reps with ~60 target customers and a “hit rate” of 4 per day, plus an alleged bullying/fear culture.
Boehringer Ingelheim responded that it set contact rates (not call rates) and distinguished unsolicited vs solicited contacts; unsolicited calls must not exceed 3 per year per prescriber.
The company described minimum target list lengths (eg 2017 minimums: PCS 120; TAS 180) and stated most interactions were group meetings, reducing risk of exceeding unsolicited call limits.
A CRM review over 24 months identified two apparent instances where the 3-per-year unsolicited limit might have been exceeded; one was later attributed to misclassification of group meeting contacts, and the other could not be confirmed because the employee had left.
The Panel noted some internal documents used inconsistent terminology (eg “calls” vs “contacts”) and did not always reference Clause 15 requirements.

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No breach of the ABPI Code (Applicable Code year: 2016).
The Panel ruled the complainant had not established, on the balance of probabilities, that the alleged small target lists and daily activity expectations were likely to lead to Code breaches.
The Panel considered the allegation about a bullying culture/being “managed out” to be outside the scope of the Code in the circumstances of this case.
The Panel asked that Boehringer Ingelheim be advised of its concerns about clarity/consistency of communications on calls vs contacts and referencing Clause 15.4 requirements.

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