In order to ensure professional and transparent conduct in our Pharmaceutical Marketing operations, we comply not only with numerous statutory regulations but have also defined our own code of conduct. In addition, the industry rules of the international umbrella organization (IFPMA – International Federation of Pharmaceutical Manufacturers & Associations), the European umbrella organization (EFPIA – European Federation of Pharmaceutical Industries and Associations) as well as the local industry associations apply. The Merck Pharmaceutical Marketing Best Practices define internationally binding standards, for example for product advertising and sponsoring. In addition to the international standards, countries have their own specific regulations.
In addition, the “Promotional Materials“ guideline, which was introduced in February 2010, applies to all Merck Serono companies worldwide. It stipulates the review and approval of advertising materials by Medical, Regulatory and/or Legal. The guideline serves to ensure that promotional materials conform to the global pharmaceutical rules within Merck Serono.
Country-specific rules supplement the international standards: For employees of the German organization, there is also an internal guideline on interacting with physicians, hospitals, pharmacies and other members of professional circles as well as patient organizations. As a member of the German Association of Research-Based Pharmaceutical Companies (VFA), Merck was one of the founders of the “Freiwillige Selbstkontrolle für die Arzneimittelindustrie e.V.” (Association for the Voluntary Self-Control of the Pharmaceutical Industry) in February 2004. As a self-control body, the association uses a code of conduct to monitor how its members cooperate with professional circles and patient organizations- When violations of the code are suspected, members and third parties can file complaints to an arbitration body. To date, there have been no complaints relating to Merck.
Since February 2010, the guideline entitled "Pharmaceutical Operations of Merck KGaA and Merck Serono S.A. in the United States“ applies to all Merck activities in the pharmaceutical sector with an impact on the U.S. market. These call for compliance with the laws, rules and statutory regulations that apply in the United States. Employees are currently being trained in the application of the guidelines. An online training course is currently being developed and is expected to be available in 2011.
We recognize the important role that patient organizations play in providing support and disseminating information to patients and their caregivers. We therefore support the educational work of various patient organizations with donations and sponsorships, encouraging them to continue their efforts. Merck explicitly does not seek to exert influence or control over the information that the organizations communicate to their members. For comprehensive transparency, we publish our donations to European patient organizations on our website and update the information annually.
