AUTH/3186/5/19: Anonymous v Almirall — Berlin psoriasis meeting arrangements (no breach) | PMCPA Case

📊

Key facts

⌄

Case	AUTH/3186/5/19
Parties	Anonymous, non-contactable v Almirall
Issue	Arrangements for a meeting (HCP selection and hospitality/entertainment allegations)
Meeting	“Psoriasis Management of Patients Over Time – PsoMOT”, Berlin, Germany (27–28 Oct 2018; arrivals/dinner 26 Oct)
Complainant	Anonymous ex-employee (non-contactable)
Allegations	Invitees selected based on prescribing; lavish hospitality; entertainment (music/cabaret); no education on Friday; Sunday 3-course lunch
Company position	International educational meeting; UK nominated delegates using defined criteria; host-country meal limit applied (€60); no entertainment; Sunday was buffet lunch (€42.35 incl alcohol)
Applicable Code	Considered under the 2016 Code (Panel noted differences vs 2019 Code for certification of meetings outside the UK)
Clauses considered	2, 9.1, 22.1
Decision	No breach of Clauses 2, 9.1, 22.1
Hospitality benchmark referenced	German Code limit €60 per meal including VAT (host-country limit applied)
Complaint received	1 May 2019
Case completed	20 August 2019
Appeal	No appeal
Published	May 2020 Code of Practice Review

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

🤖

Got a question about this case?

Ask one of our 13 specialist ABPI advisors — instant answers, 24/7.

Ask AskAnzal AI

🎬 Expert Video Walkthrough

🎬

Video walkthrough — coming for members

Subscribe now and get expert video analysis for every case as we publish them.

Subscribe — from £299/yr

📋

⌄

An anonymous, non-contactable ex-employee complained about arrangements for an international meeting in Berlin: “Psoriasis Management of Patients Over Time – PsoMOT” (27–28 Oct 2018), organised and funded by Almirall S.A (Spain), with UK doctors invited.
Allegations included: UK doctors were selected based on prescribing of Almirall products; a “lavish” dinner on Friday 26 Oct with no educational content; a Saturday dinner with a music band and cabaret dancers; and a “three course sit down lunch” on Sunday.
The complainant supplied a letter to delegates and photographs said to show entertainment at the Saturday venue.
Almirall said the event was a scientific/educational meeting with plenary lectures and workshops; UK’s role was nomination only, with criteria set out in a salesforce briefing and nominations reviewed by marketing and medical.
Almirall stated host-country (Germany) meal limit applied (€60 per meal incl VAT) and provided invoices/cost breakdowns; it denied any entertainment and said some photos were from other events and publicly available online.

⚖️

⌄

No breach of the Code was ruled.
The Panel found no evidence (on the balance of probabilities) that UK invitees were chosen based on prescribing of Almirall products.
The Panel found hospitality costs for Friday and Saturday dinners were within the German limit (€60 per head) and, taking all circumstances into account, hospitality was not unreasonable.
The Panel queried whether the Sunday buffet lunch (served ~30 minutes after the meeting ended; €42.35 per person including alcohol) was appropriate, noting it was “on the limits of acceptability”, but still ruled no breach.
The Panel did not accept that entertainment (music/cabaret) was provided, as the complainant did not evidence this on the balance of probabilities.

🔒

Members get the complete breakdown — Clauses, Sanction, Signatory Lens, Audit checklist, and 3 Key Questions.

Best value

£249/year

Annual — save £99

£29/mo

Monthly

Join Now — Instant Access