Grünenthal voluntary admission: employee missed ABPI exam first-year deadline (Clause 9.4)

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Key facts

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Case	AUTH/3799/7/23
Company	Grünenthal
Type	Voluntary admission
Issue	Failure to take the appropriate ABPI Examination within the first year of employment as a representative
Employee area	Market Access (role entailed calling upon health professionals)
Applicable Code year	2021
Breach clauses	Clause 9.4
Complaint received	14 July 2023
Case completed	12 August 2024
Appeal	No appeal
Sanctions	Undertaking received; additional sanctions: Not stated
Key dates mentioned	Employment start: February 2022; first module: 23 April 2023; should have taken modules by: 21 February 2023; passed within two years by: 21 February 2024

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

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Grünenthal made a voluntary admission about an employee in Market Access whose role involved calling on health professionals.
The employee started employment in February 2022 but did not start/take the appropriate ABPI Exam modules within the first year (first module completed 23 April 2023; modules should have been taken by 21 February 2023).
The issue was found during an internal monitoring exercise.
On investigation, the employee’s “start date in industry” had been entered incorrectly on the ABPI exams website (15 August 2022, said to be the date of the first in-field HCP call, rather than the actual start date).
No extension request was submitted when the first-year deadline was missed.
The employee subsequently completed and passed all modules within two years of the corrected start date (before 21 February 2024) and provided a certificate.
Grünenthal noted a gap in dedicated compliance resource for about one month (previous Compliance Officer left 28 April 2023; Interim Compliance Officer started 1 June 2023).

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Breach of Clause 9.4.
PMCPA Panel expressed concern about the lack of measures that could have prevented the issue and reiterated expectations for robust policies and procedures.
No appeal.

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