AUTH/2854/7/16 - Voluntary admission by Boehringer Ingelheim

Failure to certify the final form of promotional material

  • Received
    06 July 2016
  • Case number
    AUTH/2854/7/16
  • Applicable Code year
    2016
  • Completed
    08 August 2016
  • Breach Clause(s)
  • Sanctions applied
    Undertaking received
  • Additional sanctions
  • Appeal
    No appeal
  • Review
    November 2016 Review

Case Summary

Boehringer Ingelheim voluntarily admitted a breach of the Code in that a recent review of materials showed that a number of job bags had not received an extra signature to confirm that the certified electronic material matched the final printed hard copy.

In accordance with Paragraph 5.6 of the Constitution and Procedure, the Director treated the matter as a complaint.

The detailed response from Boehringer Ingelheim is given below.

The Panel noted that Boehringer Ingelheim, in its initial letter referred to 'a number' of promotional job bags which showed that the final printed copy of the material had not been checked to ensure that it matched the previously approved final electronic version. The Panel was disappointed that the company had not revealed the extent of the matter at the outset; just over 1 in 3 of a sample of nearly 275 job bags were affected (103). The problem appeared to be widespread. Nonetheless, Boehringer Ingelheim had subsequently checked the material and found that in all cases the final form matched that which had been electronically approved. However, the Code required the printed material to be checked against the electronic copy before use and this had not happened. Breaches of the Code were ruled including that high standards had not been maintained.