1. AIM OF THE POLICY
The following SciGen Marketing Policy (hereinafter “Policy”) was drawn by SciGen (“SCIGEN”) in order to provide a unified, law-abiding and ethical procedures performed by SCIGEN in the field of their advertising, promotional and marketing related activities.
2. SUBJECT OF THE POLICY
The policy defines conditions for the implementation and rules for proper execution in relevant geographical area where SCIGEN has commercial presence.
Before undertaking any actions covered by the Policy, every SCIGEN-related person is obligated to familiarize themselves with the current Policy and act in compliance to its provisions. The SCIGEN employee responsible for a given task is responsible for informing Distributors about current provisions.
In all matters of application, interpretation and enforcement of any section of this Policy, compliance with the local laws and regulation and its requirements will take precedence.
3. SCOPE OF RESPONSIBILITIES AND OBLIGATIONS
The SCIGEN Board of Directors is responsible for the overall adherence of the Policy.
Every person who executes actions covered by the Policy on behalf of SCIGEN is responsible for maintaining compliance of their actions with the Policy.
For the purposes of the Policy, the following terms used in the Policy or attached documents are defined as follows:
5. REQUIREMENTS FOR PROMOTIONAL ACTIVITIES
Promotional activities covered within the scope of the Policy shall include but are not exclusive to the following:
It shall be the responsibility of SCIGEN to ensure that all advertised information is correct and truthful and any (health and/or medical) claims relating to a particular
medicinal product must be aligned with the appropriate use of the labelled indication and the category of medicinal product classification.
SCIGEN must ensure that all medical advertisements fulfil the following criteria:
All medical advertisement and sales promotion materials will be evaluated by the compliance and/or regulatory department(s) for appropriateness and ensure that the sales promotion mechanics are alignment to this Policy prior to distribution to the public.
6. POST-APPROVAL MARKETING SURVEILLANCE
SCIGEN may conduct or engage its Distributor to conduct post-marketing surveillance studies following registration approval. SCIGEN shall supply the Distributor, as needed, the quantities of product as agreed upon for it to reasonably conduct the study. The study must be conducted in compliance with local laws and regulations.
SCIGEN shall, to its best knowledge, assist to answer any questions pertaining to the product that arise prior to, during or post to the study.
All forms of incentives offered to the subjects of the surveillance study, if any, shall be to compensate for the work involved. No product shall be provided to the subjects at the end of the study.
Sponsoring of a health care programme for both local and overseas meetings must conform to the professional standards of ethics. The following criteria must be fulfilled:
Sponsorship to any individual is limited to travel, accommodation and registration fees for overseas meeting. Such support to any individual must not be conditional upon any obligation to prescribe or promote SCIGEN products.
Request for sponsorship shall be approved in advance via submission of Sponsorship Request Form (Appendix 1).
No entertainment shall be offered to any individual to influence them in the prescription, recommendation or promotion of products, nor to gain favour for SCIGEN.
For any meeting or conference, entertainment should be secondary to the main purpose of the meeting or conference. Venue of entertainment shall be conducive to the purpose of the meeting and conforms to professional ethics.
No gifts shall be offered to any individual to influence them in the prescription, recommendation or promotion of products, nor to gain favour for SCIGEN. Payments in cash or cash equivalents (such as gift certificate) to is strictly prohibited.
As an exception to the above, as long as they are not forbidden by current legislation, gifts of modest values are allowed when they correspond to signs of courtesy or to local cultural norms.
If the receiver is a Health Professional, we must also adhere to the codes of conduct that are applicable in the country where they carry out their profession.
Request for sponsorship shall be approved in advance via submission of Gift Request Form (Appendix 2).
Donation is strictly for charitable purposes and must be:
Request for donation must be submitted by Country Manager and substantiated by written documentation of aid required and its beneficiaries.
Donation must be jointly approved by Chief Executive Officer and Chief Financial Officer for amounts up to USD10,000. Any amount above USD10,000 must be approved by the Board of Directors.
Request for donation shall be approved in advance via submission of Donation Request Form (Appendix 3).
Provision of “samples” as an inducement to purchase is strictly prohibited.
Reasonable quantities of samples must be clearly identified as “samples”, may be supplied to the prescribing Healthcare Professional to familiarise them with the product and to gain experience regarding efficacy and side-effects of the product.
Samples must not be sold.
Samples must be kept in a conducive environment in compliance with regulations.
Expired samples must not be distributed and must be destroyed according to SCIGEN internal SOP procedure and subject to local regulation.
Where samples of products restricted by law to supply on prescription are distributed by a sales representative, the sample must be handed directly to the doctor or to a person authorised to receive the sample on the doctor’s behalf.
Sales representatives must account for the distribution of samples and return the list of sample inventory to logistic personnel.
12. RESPONSIBILITY FOR POLICY INFRINGEMENT
SCIGEN has a complaints and queries channel which will enable all the staff to send in queries about this Policy in full confidence, as well as to report possible infringements or violations of it.
Infringement of Policy provisions exposes SCIGEN to material and non-material damage. Therefore, disciplinary actions will be taken against any employee, who infringes the Policy provisions.
Policy infringement may also be regarded as severe worker misconduct and may result in employment contract termination without notice due to the employee’ fault.
An employee who becomes aware of other person infringing the Policy provisions, is obliged to report this immediately to their immediate superior, or the Head of Human Resources Department.
The immediate superior and the head of Human Resources Department shall immediately report this infringement information to the Chief Executive Officer, unless in their opinion there is lack of evidence of infringement. In such cases, they shall document receipt of report and their opinion with a memo.
The complaints which can be substantiated by evidence will be escalated to the Board of Directors for review. Remedial actions must be taken as soon as possible after each review.
Database of complaints, review findings and action plans must be archived at the corporate headquarters in Singapore and respective subsidiaries’.