Cipla: failure to evidence HCP interaction records led to Clause 5.1 breach (AUTH/3887/4/24)

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Key facts

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Case number	AUTH/3887/4/24
Company	Cipla (EU) Limited
Complainant	Anonymous, non-contactable; described themselves as a pharmaceutical company employee
Allegation	Failure to keep records of company interactions with HCPs for a number of years (including 1:1 calls, meetings, conferences)
Applicable Code year	2021
Panel finding	Failure to evidence capture of representative interactions with HCPs for nearly two years (Aug 2022–Jul 2024) meant failure to maintain high standards
Breach clauses	Clause 5.1
No breach clauses	Clause 2
Sanctions	Undertaking received; Additional sanctions: Not stated
Complaint received	02 April 2024
Case completed	16 July 2025
Appeal	No appeal

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

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An anonymous, non-contactable complainant alleged Cipla kept no records of interactions with healthcare professionals (HCPs) for several years (including 1:1 calls, meetings, and conferences).
Cipla said it had processes and that contract teams used CRM systems; it also said Key Account Managers (KAMs) previously kept Excel records and a new CRM was implemented in July 2024 (after the complaint).
The Panel repeatedly requested evidence of the alleged Excel records for 2021–2023 / the period between Aug 2022 and Jul 2024.
Cipla provided reports from contract teams showing interactions captured up to Aug 2022, but did not provide evidence of records for the subsequent period.
The Panel noted Cipla’s KAM meeting approval materials referenced a “Meeting Attendance form” and “collation of attendee list”, suggesting some expectation of recording attendance, but this did not evidence comprehensive interaction records for the missing period.

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Breach of Clause 5.1 (Failing to maintain high standards).
No breach of Clause 2 (Requirement that activities or materials must not bring discredit upon, or reduce confidence in, the pharmaceutical industry).

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