U.S. Pharmaceutical Product Promotion and Marketing
Over the past several years, there has been an increased focus on pharmaceutical promotional practices. The American Medical Association (AMA) launched an educational campaign on "gifts to physicians," the Pharmaceutical Research and Manufacturers of America (PhRMA) issued a new code on interactions with healthcare professionals, and the Department of Health and Human Services Office of Inspector General (HHS-OIG) published Compliance Program Guidance for Pharmaceutical Manufacturers. Wyeth supports each of these initiatives.
Wyeth favors education with the goal of improving patient care. Our Company's contribution to legitimate education of healthcare professionals is an important part of the educational process within the healthcare community. Overall the pharmaceutical industry provides funding for valuable education which otherwise would not exist. The dissemination of information about products enhances the ability of physicians and patients to make informed decisions. Wyeth does not pay healthcare providers to listen to product messages or in order to influence or reward prescribing activity. If a consultant or speaker is used, the individual is compensated fairly for his or her services.
Wyeth Compliance Program
Wyeth is committed to ensuring that its business is conducted in an ethical manner and has been at the forefront in adopting guidelines from the AMA, PhRMA, and (HHS-OIG).
To ensure compliance with the laws, industry guidelines and Wyeth standards applicable to the sale and marketing of our products, the Company established a formal compliance program, which we call the Good Promotional Practices program that is consistent with the HHS-OIG Guidance. The Company designated a full-time Compliance Office with responsibility for developing, operating and monitoring this program. The Chief Compliance Officer makes periodic reports to the Audit Committee of the Board of Directors and has the authority to report significant issues directly to the Board of Directors and the CEO of the Company. The program is overseen by a compliance committee composed of senior executives of the Company's pharmaceuticals division, who advise the Chief Compliance Officer and assist in the implementation of the GPP program.
The Wyeth Code of Conduct summarizes the ethical and legal standards to which all Wyeth employees must adhere in many areas, including the promotion, marketing and sale of the Company's pharmaceutical products. In addition, specific policies and procedures are written and revised as needed. These policies help ensure compliance with the PhRMA "Code on Interactions with Healthcare Professionals" and include limits on gifts or incentives to healthcare professionals.
Wyeth supports appropriate promotion and marketing practices through the training and certification of our employees. The Company provides a toll free telephone line for employees and contractors to report suspected violations of Company policies or legal requirements. Calls can be made anonymously and without fear of retribution 24 hours a day seven days a week. Reports of suspected non-compliance are documented and investigated so that appropriate corrective action can be taken when warranted. The compliance program and the Company's promotion and marketing practices are audited on a routine basis to ensure that these activities comply with all federal healthcare program requirements and meet Wyeth's goals for high ethical standards in the conduct of its business.
To the best of our knowledge and based on our understanding of the statutory requirements, the Company has established a comprehensive compliance program in accordance with the requirements of California Health and Safety Codes, Sections 119400-119402 and complies with the program in all material respects. Additional information regarding the GPP Program and this declaration can be obtained by contacting the Chief Compliance Officer, at 1-866-423-4864.