Ethical Promotional Activities
As a corporate group undertaking business that is deeply connected to people’s lives and health, the Kyowa Kirin Group must strive to engage in promotional activities by consistently upholding a high standard of ethics.
To articulate its commitment to ethical promotional activities, the Group has established the Kyowa Kirin Group Promotion Policy in line with the Japan Pharmaceutical Manufacturers Association (JPMA) Code of Practice. In addition to complying with the proprietary policy, the Group also adheres to relevant laws and regulations of each country in which it conducts business, codes of conduct and guidance set by the International Federation of Pharmaceutical Manufacturers and Associations (IFPMA) and regional industry associations.
Kyowa Kirin Group Promotion Policy
Revised on June 1, 2020
We at the Kyowa Kirin Group (hereafter, referred to as "Our Group") consider promotion to be an important activity from the standpoint of letting the people of the world know the value of the Group's products and giving them the opportunity to experience the value. Promotion must never be performed by inappropriate methods or to obtain undue profit.
As a group of corporations involved in a business that is deeply invested in people's lives and health, the Group engages in ethical promotion with healthcare professionals to provide timely and truthful information that is scientifically and clinically significant when marketing our products.
"promotion" means any activity undertaken, organized or sponsored by a member company which is directed at HCPs to promote the prescription, recommendation, supply, administration or consumption of its pharmaceutical product(s) through all channels of communications .
- 1.Communication with healthcare professionals
We will communicate with healthcare professionals aiming to benefit patients and enhance the practice of medicine, by focusing on providing valid scientific and educational information. - 2.Independence of healthcare professionals
We will not provide and offer gifts, financial gain and/or benefits (e.g. scholarships, grants, consultant contracts, travel and accommodation upgrade, etc.) to healthcare professionals in exchange for the prescription, recommendation, purchase, administration of our medicinal products or the promise to continue these practices or as a reward for these practices in the past. We will not provide or offer any information in a manner or under conditions that may improperly affect the prescribing practices of healthcare professionals. - 3.Proper use of drugs
We will promote the proper use of pharmaceuticals in an accurate, fair and balanced manner by presenting the characteristics of pharmaceuticals objectively and without exaggeration. - 4.National regulations of each country
We will abide by any applicable laws to laws, guidelines and industry rules on promotion in the countries and regions where our group operates. We will follow the IFPMA codes when conducting activities in countries or regions that do not have proper laws and regulations or industry codes. - 5.Organization
We will establish and operate appropriate organizational structures and business processes that comply with laws and regulations and industry codes in countries and regions where we operate.
System
Kyowa Kirin provides information materials, including those pertaining to its pharmaceuticals and products in related fields, advertisements and materials for patients, only after ascertaining their full compliance with relevant laws and regulations of applicable countries and standards set by industry associations.
In Japan, such information materials are reviewed by multiple relevant divisions independent of the sales division as well as by the Information Materials Review Committee, whose members include third parties. Information materials are reviewed from the viewpoints of their scientific validity and whether they comply with the JPMA Code of Practice, fair competition rules and other external standards. The sales division that uses the applicable information materials is not involved in the review process. All divisions are prohibited from using information materials that have not been reviewed and approved.
In our efforts to comply with the Guidelines for Provision of Sales Information on Prescription Drugs set forth by the Ministry of Health, Labour and Welfare (hereinafter, “Guidelines”), we have also established a system for checking that sales information is provided in an appropriate manner.
Specifically, we have a division that supervises our activities for providing sales information by way of monitoring and providing guidance to ensure that they are conducted appropriately. Moreover, when providing information on off-label uses of the Group’s pharmaceuticals or unapproved drugs under development by the Group, we ensure compliance with relevant laws and regulations.
Furthermore, we have in place a committee for supervising our sales information provision activities, whose members include third parties, to oversee and guide such activities. The supervisory department for information material review periodically reports to the committee and seeks advice.
Training Programs
Employee training is a key factor in ensuring ethical promotional activities.
Training is offered periodically to employees who create information materials and those who engage in promotional activities. Programs include in-person classes given by sales office managers and members of the CSR Management Department, as well as online-based and e-learning courses.
An annual Compliance Promotion Month has been established, with all employees required to undergo a training program to learn about and better understand the code of practice. In the event of any violation of the code, additional training is promptly conducted to prevent recurrence.
You can see this table by scrolling horizontally.
| Training organizer | Target | Frequency | Scope of training |
|---|---|---|---|
| CSR Management Department | Personnel in charge of creating materials | 12 times a year | Knowledge required to create materials in compliance with laws and regulations |
| Sales office manager | Sales & Marketing Division | 12 times a year | Guidelines, fair competition rules |
| CSR Management Department | Medical Information Department, Sales & Marketing Division |
4 times a year | JPMA Code of Practice, guidelines, fair competition rules |
| CSR Management Department | All employees of Kyowa Kirin Group (in Japan) | Once a year | JPMA Code of Practice |