Do the requirements of the Code apply to third parties working on behalf of a pharmaceutical company?

Yes. Companies are responsible for third parties working on their behalf or under their instruction, paid or otherwise.

The definition of third party is set out in Clause 1.24 and means a legal person/entity or individual that represents a company or interacts with other parties on behalf of a company or relating to a company’s medicine, such as distributors, wholesalers, consultants, contract research organisations, professional congress organisers, contracted sales forces, market research companies, advertising agencies, media buyers, providers of services related to events, public relations services, non-clinical services, non-interventional studies management services, etc.

Companies are responsible under the Code for the acts and omissions of their third parties which come within the scope of the Code, even if they act contrary to the instructions which they have been given.