MR Code of Conduct
MR Code of Conduct
EphMRA PHARMACEUTICAL
MARKET RESEARCH CODE OF CONDUCT
Published: June 1997
INTRODUCTION
Pharmaceutical marketing research must always
be conducted in full conformity with the principles laid down in
the ICC/ESOMAR International Code of Marketing and Social Research
Practice (1995). Because of the special characteristics and
requirements of pharmaceutical research, however, it is necessary
to specify how certain of these principles should be applied in
this field of research and also to add a few further principles of
conduct. These are set out in the Articles which follow.
The requirements of this and the main
ICC/ESOMAR Code apply equally to research carried out directly by a
department of the pharmaceutical company concerned (using either
its own staff or outside interviewers sub-contracted for this
purpose) and to research carried out by another organisation acting
on the company's behalf.
Throughout these Codes the term "respondent"
applies both to individual persons and to the organisations to
which they belong and about whom they may be providing
information.
In the ICC/ESOMAR International Code Rule 2
points out, marketing research must always also conform to the
national and international legislation which applies in those
countries involved in a given research project.
Attention is called in particular to certain
additional restrictions which apply in Germany and which are set
out in a special 'Declaration' ('Erklärung') attached to the
German-language version of the Code.
GENERAL CONSIDERATIONS
Marketing research must be unbiased and
non-promotional. While research statistics and the information
derived from them may subsequently be used for promotional
purposes, the two activities of information collection and
information use must be kept distinct. Marketing research must not
be used as a direct means of promoting sales or influencing the
opinions of respondents. Also, research must never be carried out
in a way which could bring discredit upon, or reduce confidence in,
the pharmaceutical industry.
1.1 A survey
should not imply that it is independent of the pharmaceutical
industry if it is in fact commissioned by, or for, one or more
pharmaceutical companies.
1.2 Any questionnaire or research guideline
used in pharmaceutical marketing research must avoid creating any
impression that it seeks to disparage competing products or
companies.
RESPONSIBILITIES TOWARDS RESPONDENTS
2.1 Doctors have a duty of confidentiality
towards their patients. They can provide information about such
patients in connection with a marketing research project only if
this information is given in anonymous form, or as provided for
under Article 2.2(b).
2.2 It is permissible for doctors to
co-operate in a marketing research project among their
patients:
(a) by acting as the intermediary between the
researcher and appropriate patients by themselves inviting these
patients to take part in the study (making clear to them that their
co-operation is entirely voluntary), giving the questionnaires to
the patients and returning the completed questionnaires to the
researcher in anonymous form so that the identities of the patients
concerned are at no stage revealed to the researcher, and/or
b) by passing on to appropriate patients,
without at that stage disclosing their identity to the researcher,
an invitation from the latter to participate in the survey. Any
patients approached in this way can then choose whether or not they
wish to co-operate in the survey, and if so, whether they agree to
the disclosure of their names to the researcher. Such agreement on
the part of a patient must be in writing.
2.3 If information is being collected from
respondents not by researchers but by sales representatives the
latter must not represent themselves as belonging to a research
organisation or department. They must make clear to the respondent
their position and the company for which they work, and that while
they are seeking information they are not conducting a confidential
marketing research interview.
2.4 Where interviews or group discussions with
doctors and other 'professional' respondents are recorded on audio
- or video-tape the respondents' anonymity must be rigorously
safeguarded. The required safeguards are set out in the
ESOMAR Guideline on "Tape and video-recording and client
observation of interviews and group discussions (1996)".
2.5 Marketing research must never be used in
order to obtain confidential information about competitive products
and companies from respondents who are bound by confidentiality
agreements with those competitors.
RECOMPENSE OF RESPONDENTS
3.1 Where an interview is conducted with a
'professional' respondent such as a doctor, or with a member of
staff of an organisation such as a hospital, it may be necessary
and appropriate to recompense that person or organisation for the
amount of their working time taken up by the interview. Such
incentives or rewards to respondents should be kept to a minimum
level proportionate to the amount of their time involved, and
should not be more than the normal hourly fee charged by that
person for their professional consultancy or advice.
RELATIONS WITH THE GENERAL PUBLIC AND THE
BUSINESS COMMUNITY
4.1 Research among the general public which
relates to current or potential new developments or treatments in
the medical field must be carried out in a balanced and factual way
so as to avoid the dangers:
(a) of raising unfounded hopes of successful
treatment of specific medical problems
(b) of misleading the public with respect to
the safety of a product
(c) of encouraging members of the public to
ask their doctor to prescribe a particular product.
4.2 When a marketing research project includes
the actual usage by a respondent of active substance or any other
medication or medical application which might cause an allergenic
or other undesirable effect it must be carried out according to GCP
(Good Clinical Practice) guidelines.