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PMCPA Case

AUTH/3762/4/23: Complainant v SyriMed (Thame Laboratories) — representative exam allegation (No breach)

📅 2023 | 🖉 Dr Anzal Qurbain
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Key facts

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Case numberAUTH/3762/4/23
PartiesComplainant v SyriMed (Thame Laboratories)
Complaint received10 April 2023
Case completed7 June 2024
Applicable Code year2021
IssueAlleged promotion to health professionals for >2 years without requisite representative qualification/exam
Products mentioned“Alfredo’s” (SyriMed said this referred to Alfresed), Miprosed, Zacco
Panel view on representative statusOn the balance of probabilities, acting as a Representative from 4 November 2022
DecisionNo breach of Clauses 5.1 and 9.4
AppealNo appeal
SanctionsNone stated

Download the full case report (PDF)

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

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What happened

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  • An ex-employee alleged a named employee had been marketing/promoting branded medicines to GPs, pharmacists and hospital clinicians for more than two years without the requisite representative qualification (ABPI course/exam).
  • The products named in the complaint were “Alfredo’s” (company said this referred to Alfresed), plus Miprosed and Zacco.
  • SyriMed said the employee’s role from 2012 was administrative/commercial (orders, queries, pricing, stock) with wholesale/retail customers, not HCP promotion.
  • SyriMed said the employee’s title later included “sales” (2020) but duties remained administrative support (data reporting; arranging printing of already-approved materials).
  • From 4 Nov 2022, following restructuring, the employee began supervised training for a potential market access role; SyriMed said communications were limited to previously approved commercial information (eg pricing/savings/availability) and the employee shadowed presentations.
  • The Panel noted the complainant provided no evidence; PMCPA is not an investigatory body and decides on evidence provided by the parties.
  • The Panel considered that, given the broad definition of promotion, the employee was acting as a “Representative” (as defined by the Code) from 4 Nov 2022 because they were required to attend meetings with health professionals about SyriMed’s medicines and communicate product information such as savings.
  • The Panel noted Clause 9.4 requires representatives to take an appropriate examination within the first year (attempt all modules), not merely “register” for it.
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Outcome

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  • No breach of Clause 9.4 (Requirement that representatives take an appropriate examination within their first year of employment as a representative and pass it within two years of starting such employment).
  • No breach of Clause 5.1 (Requirement to maintain high standards at all times).
  • No appeal.
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