ABPI Compliance or Risky Business?Three Common Grey Areas Explored
- Sep 5, 2025
- 2 min read
Some areas of the Code aren’t as black and white as they seem. We can’t
judge a book by It’s cover.
Here are three scenarios we sometimes get asked, “Is this okay?” let’s break them down.
“Are you sure I can mention my product to the Public?”
The Scenario: A Pharma company runs a disease awareness campaign aimed
at members of the public. The materials provide factual information about a condition, include treatment options, and feature the company’s corporate branding.
✔ Compliant or Not?
✔ Compliant (with caveats). Disease awareness materials are technically allowed to name a product if they remain factual, non promotional, and balanced.
Be cautious: Focus on the disease and not the treatment. Overemphasising a particular treatment could be seen as promotion.
Key Takeaway: Keep materials about the condition and not treatment focused. Ensure they don’t favour one treatment over another.
“Surely I can share a KOL’s thoughts with my network?”
The Scenario: A Key Opinion Leader (KOL) posts about a medicine, sharing their positive experience using it with patients. A pharmaceutical company shares the post on their LinkedIn to highlight expert perspectives.
✔ Compliant or Not?
Not compliant. Even though the thoughts are from an independent HCP, resharing the content as a Pharma company will be seen as promotion especially if the post discusses a specific medicine.
Key Takeaway: Have a clear internal policy on social media interactions. Only share content that is non promotional ideally pre approved.
“Can I really buy a doctor dinner?”
The Scenario: A pharmaceutical company invites a small group of HCPs for an educational meeting at a mid range restaurant. The company covers the cost of a modest meal and non alcoholic drinks.
✔ Compliant or Not?
✔ Compliant. The ABPI Code allows hospitality, provided it is:
Appropriate and modest - No excessive costs or extravagant venues.
Secondary to education - The primary focus must be scientific exchange.
Key Takeaway: Keep hospitality reasonable, proportionate, and justifiable.
Ensure education is the primary reason for attending.
Even seemingly simple decisions covering a meal, running a campaign, or engaging with social media can have major implications.
The ABPI Code is all about context, and staying on the right side of the rules requires
careful thought, clear guidelines.
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