Implementation and enforcement

Each unit has set up a local Promotional Clearance Committee (PCC) to ensure adherence to the relevant codes. Finally, compliance with NP⁴ across the Pharmaceuticals Division is verified by Group Auditing and supported by external assurance processes.

In 2006, the Pharmaceuticals Division streamlined the function of our promotional clearance committees. New clearance procedures to review promotional materials and other business activities to ensure compliance with local regulations, as well as internal and external marketing codes, were piloted in the US and certain European countries and will be introduced into additional markets throughout 2007. Also in 2006, Internal Audit completed Code of Conduct and marketing policy audits in 28 country organizations. The findings - including gaps related to promotional practices - are being addressed by local management.

In recognition of the market pressures often faced by sales and marketing associates and to support them in upholding our ethical marketing standards, 'creative competitiveness' workshops were initiated in the US, Germany and Spain to train the local clearance committee members who review and approve promotional activities. The objective was to foster creativity in decision-making without compromising our ethical standards.

As part of our wider efforts to raise standards of integrity in marketing across the pharmaceutical sector as a whole, January 2007 saw the launch of a new International Federation of Pharmaceutical Manufacturers Associations (IFPMA) code of marketing ethics for the global pharmaceutical industry. Novartis Chairman and CEO Dr. Daniel Vasella oversaw reform of the code as IFPMA President (2004-2006).

The new code sets standards for ethical promotion of pharmaceutical products and member companies' interactions with healthcare professionals. In addition, it clarifies guidelines for events, sponsorships and other types of promotion; sets limits on entertainment and social activities funded by member companies; and restricts personal gifts for healthcare professionals.

As part of our ethical marketing practices, Novartis is committed to providing scientifically sound, relevant and appropriate information to healthcare professionals and patients.