Ipsen voluntary admission: employee promoted to HCPs in Northern Ireland without verified ABPI representative exam (AUTH/3839/10/23)

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Key facts

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Case number	AUTH/3839/10/23
Company	Ipsen Limited
Case type	Voluntary admission
Issue	Failure to verify/passage of ABPI medical representative examination for an employee calling on HCPs in Northern Ireland
Geography	Northern Ireland (employee previously in Ireland-only role)
Applicable Code (Panel applied)	2019 Code (Clauses 9.1 and 16.3)
Breach clauses	Clause 9.1; Clause 16.3
Sanctions	Undertaking received; Additional sanctions: Not stated
Complaint received	16 October 2023
Case completed	18 September 2024
Appeal	No appeal

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

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Ipsen identified (via an internal audit) that one employee in a promotional, customer-facing role calling on health professionals in Northern Ireland had no ABPI representative exam certificate on file and the ABPI could not confirm completion.
The employee had moved internally from an Ireland-only promotional role (not subject to ABPI representative exam requirements) to a Northern Ireland promotional role in January 2019.
The employee had been calling on customers for over 15 months without Ipsen verifying the required qualification and without applying for any training exemption.
On discovery (April 2020), Ipsen instructed the employee to cease all promotional activity and work only in a non-promotional capacity.
Ipsen submitted a voluntary admission to the PMCPA in October 2023.
Ipsen updated SOPs/processes so HR would check and record ABPI exam certificates for new starters and for employees transitioning into promotional roles (including contractors providing temporary cover).

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Breach of Clause 16.3 (2019 Code) ruled (as acknowledged by Ipsen).
Breach of Clause 9.1 (2019 Code) ruled due to lack of robust process/due diligence when employees transferred roles and concerns about onboarding robustness.
No appeal.

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