Trust and confidence are key to building strong, productive relationships.
At Innovative Medicines Canada, we work together with the broader healthcare community toward the long-term sustainability of a healthcare system in which patients experience the best possible health outcomes.
We and our members have set a high standard for ethical, transparent and open practices that respect the relationships among our member company employees, the life sciences sector, healthcare professionals and the Canadian public.
All our members are bound by our Code of Ethical Practices, which maintains strict standards on what is acceptable in our work with healthcare practitioners. Our members are responsible to ensure their business engagements with stakeholders comply with the Code. We do not preclear any activity undertaken by our members or their contractors, but we publicly report on Code violations.
In addition to upholding our own Code, Innovative Medicines Canada is a member of the International Federation of Pharmaceutical Manufacturers & Associations and adheres to the IFPMA ethos, which calls for building a culture of trust.
Since 1988, our Code of Ethical Practices has demonstrated our commitment to nurturing relationships with healthcare providers that are based on trust, openness and transparency.
The Code is our commitment to all Canadians. It establishes clear guidelines to ensure the health and well-being of people is always our first priority.
Our Code of Ethical Practices guides the activities of all our members’ employees as they interact with stakeholders to commercialize prescription medicines (excluding medical devices and over-the-counter products). Adherence to the Code is a condition of membership.
If you have questions about the Code, please contact Lama Abi Khaled at labikhaled@imc-mnc.ca or by phone at 613-236-0455 ext. 236.
With our Code of Ethical Practices app, we’re making it easier for our stakeholders to access and share information about the Canadian pharmaceutical landscape – including IMC news releases and other useful resources. Members can use their company PIN to access our e-learning program and quizzes.
Our members can use this dynamic online tool to help their partners understand the Code of Ethical Practices that guides the innovative pharmaceutical industry. Use the short videos, interactive features and Q&A segments to help your partners understand how the Code guides your day-to-day interactions.
Innovative Medicines Canada used its Code of Ethical Practices as we worked with partners to build the Canadian Consensus Framework for Ethical Collaboration. The Framework is a collective solution endorsed by the Best Medicines Coalition, Health Charities Coalition of Canada, the Canadian Medical Association, the Canadian Nurses Association, the Canadian Pharmacists Association and Innovative Medicines Canada.
We are committed to ensuring that relationships among patients, healthcare professionals, and the pharmaceutical sector are based on ethical and responsible decision-making. The Framework guides individuals and organizations about activities such as clinical trials, continuing health education, conferences, accountability and funding. It is founded on four overarching principles:
The Framework aims to improve relationships. Similar to our goals with Innovative Medicines Canada’s Code of Ethical Practices, we expect the Framework to encourage better dialogue, trust and respect among patient organizations, healthcare professionals and the pharmaceutical industry.
We also aim to improve public confidence in the healthcare institutions that protect the well-being of Canadians. We designed the Framework to help create an environment where patient organizations, health care professionals and industry can have authentic discussions about improving patient outcomes.
Leading Canadian health organizations developed the Canadian Consensus Framework for Ethical Collaboration
to create a set of ethical standards to guide collaboration among patient organizations, health care professionals
and the pharmaceutical industry
The Canadian Consensus Framework for Ethical Collaboration represents leading health
organizations who have created a set of ethical standards to guide collaboration among
patient organizations, health care professionals and the healthcare industry.
Innovative Medicines Canada is just one of many pharmaceutical associations worldwide. As members of the International Federation of Pharmaceutical Manufacturers & Associations (IFMPA), we and the industry we represent have sent a clear signal that we are committed to ethical practices.
We have demonstrated our leadership in many other ways. IMC introduced APEC’s Mexico City Principles for Voluntary Codes of Business Ethics in the Biopharmaceutical Sector, a set of international ethical standards. And we were instrumental in bringing together the international Consensus Framework for Ethical Collaboration, which has four overarching principles:
The international Framework enabled Innovative Medicines Canada to engage a large group of stakeholders in discussions related to ethics, share and gather information, and promote organizations’ common approaches to ensuring high-quality patient care.
The Framework was developed in partnership by The International Alliance of Patients’ Organizations, International Council of Nurses, International Federation of Pharmaceutical Manufacturers and Associations, International Pharmaceutical Federation and the World Medical Association. It provides a structure for health organizations wishing to build their own ethical guidelines. The Framework also establishes a method for these parties to collaborate and achieve common goals.
Amendments to IMC’s Code of Ethical Practices were approved by our Board of Directors. Key amendments include the following:
IMC member companies may support healthcare professionals’ (HCPs) learning activities. Before supporting learning activities, members must conduct a needs assessment to ensure there is a legitimate unmet learning need.
While the Code continues to reiterate that full editorial control remains with HCPs, if requested by presenting HCPs, members’ medical or education personnel may now assist an HCP in developing its presentation by providing fair, balanced and objective materials that help meet the learning need.
The Code recognizes that sales representatives may perform logistical activities associated with learning programs. Members must now ensure there is appropriate internal oversight for those logistical activities. For accredited learning programs, sales representatives can perform logistical responsibilities in accordance with the National Standard for Support of CPD Activities. Also, the Code now clarifies that if member sales representatives attend learning activities, they must not participate in the discussion, and cannot detail, provide samples, or set up a booth.
The Code creates a set of standards for members who provide support to journal clubs and rounds. All support must be in the form of a grant that the program organizer can use to pay for expenses. To receive support from members, journal clubs and rounds must take place in a setting that is conducive to learning. If program organizers allow, members may attend these activities as observers.
The Code clarifies that, while member employees cannot hold in-person, face-to-face meetings with HCPs in a personal residence, the prohibition does not apply to virtual meetings.
This information has been provided for members of the pharmaceutical industry, healthcare professionals, and members of the general public who may wish to lodge a complaint under Innovative Medicines Canada’s Code of Ethical Practices. Complaints are received, reviewe and adjudicated by Innovative Medicines Canada’s Industry Practices Review Committee.
Your complaint must follow the process set out here. If it does not, Innovative Medicines Canada may reject your complaint without notice.
You must submit your complaint in writing (by mail or email) to Innovative Medicines Canada. We do not accept verbal, telephone or fax complaints. Address your complaints to:
Innovative Medicines Canada
Attention: Executive Director, Ethics & Compliance
c/o Director of Industry Practices
55 rue Metcalfe Street, Suite 1220, Ottawa, ON K1P 6L5
Complaints may be submitted to the following email address: complaint@imc-mnc.ca
Make it clear which Innovative Medicines Canada member company you are making a complaint against. Our Code of Ethics applies only to Innovative Medicines Canada members and does not apply to generic drug companies or innovative pharmaceutical companies that are not members.
When you make a complaint, you must identify yourself, as well as any company, organization, or association you are affiliated with. Provide your full return address and contact information. We will not consider anonymous complaints or complaints that do not have adequate contact information.
If you have not identified yourself as a complainant to the company you are making a complaint against, Innovative Medicines Canada will not identify you during the investigation and adjudication process. (Member companies making complaints are encouraged to identify themselves.)
However, if you or the member company you are making a complaint against appeals a decision by the Industry Practices Review Committee, we will disclose your identity and we will require you to participate in the arbitration process. If you choose to discontinue the complaint when the member company appeals, we will not disclose your identity.
You must set out in writing as much specific information as possible about your complaint. You may submit evidence in the form of documentation and/or photographs, but Innovative Medicines Canada may not return the materials you submit. Providing timely, clear, and accurate information will greatly assist in the processing of the complaint. International Pharmaceutical Research Centre (IPRC) will not consider complaints sent to us more than 120 days after you learned about the events (or reasonably ought to have learned about them).
If at all possible, you should set out what section(s) of the Code of Ethical Practices you believe has been violated. Correct references to the Code will facilitate the processing of a complaint.
Before your complaint is formally reviewed by the IPRC, the Director of Industry Practices will attempt to engage the disputing parties in an exchange of information. This normally involves the Director of Industry Practices seeking a written response to the complaint by the member company you are making a complaint against. If the member agrees, this response will be shared with you. If you wish to withdraw the complaint, the complaint process is terminated at this point. The Director of Industry Practices will send you and the member company a letter confirming that the file has been closed. Otherwise, the Director of Industry Practices will refer the complaint file to the IPRC for adjudication.
For Innovative Medicines Canada to process and adjudicate your complaint, we may have to send follow-up enquiries. If you fail to respond to our enquiries, we may discontinue the complaint process.
Do not direct complaints about member company advertising issues to Innovative Medicines Canada. Please direct them to the Pharmaceutical Advertising Advisory Board (PAAB) at:
Pharmaceutical Advertising Advisory Board
375 Kingston Road
Pickering, ON
LIV IA3
You may submit your complaints in either English or in French.
Innovative Medicines Canada wants to make sure that all complaints are filed by the complainant in good faith. We reserve the right to reject complaints that we find frivolous, vexatious and abusive to Innovative Medicines Canada and/or its member companies, moot or otherwise made in bad faith.
Note: Innovative Medicines Canada reserves the right to reject any complaint, without further notice, that does not follow the above requirements.
The Code sets out various timeframes for the processing and adjudication of complaints. While the IPRC and Innovative Medicines Canada staff attempt to adhere to these timeframes wherever reasonably possible, logistics and other commitments of volunteer members may make it impossible. In an effort to minimize possible scheduling conflicts between the members, the IPRC will pre-schedule at least four meetings throughout the year. IPRC and Innovative Medicines Canada staff will attempt to ensure that any delays do not unduly prejudice either party to a complaint.
Innovative Medicines Canada encourages transparency, especially in relation to its Code of Ethical Practices. A record of all Code-related complaints (i.e. the number of complaints lodged, withdrawn, rejected or adjudicated) will be made available on the members’ websites. Only where the IPRC determines an infraction will the member’s name be published on members’ websites.
Company X vs Company Y
Summary: Company X alleged that Company Y’s patient support programs violate sections 1.1 (Guiding Principles), 14.1.1 (Patient Support Programs), 14.2.2 (Ensure integrity of the industry), and 14.2.3 (Conflict of Interest) of the Innovative Medicines Canada Code of Ethical Practices (the “Code”).
Status: No Infraction
Breach: No Breach
Complaint Completed: January 10, 2018
Company A vs Company B
Summary: Company A alleged that Company B’s patient support programs violate Guiding Principles 2, 3, 8, as well as sections 2.1 (Privacy of Patient Information), 14.1.1 (Patient Support Programs), 14.2.2 (Ensure integrity of the industry), and 14.2.3 (Conflict of Interest) of the Innovative Medicines Canada Code of Ethical Practices (the “Code”).
Status: No Infraction
Breach: No Breach
Complaint Completed: December 20, 2016
Company C vs Company D
Summary: Company C alleged that Company D’s patient support programs violate Guiding Principles 2, 3, 8, as well as sections 2.1 (Privacy of Patient Information), 14.1.1 (Patient Support Programs), 14.2.2 (Ensure integrity of the industry), and 14.2.3 (Conflict of Interest) of the Innovative Medicines Canada Code of Ethical Practices (the “Code”).
Status: No Infraction
Breach: No Breach
Complaint Completed: December 20, 2016
Company X vs Company Y
Summary: Company X alleged that Company Y’s patient support programs violate Guiding Principles 2, 3, 8, as well as sections 2.1 (Privacy of Patient Information), 14.1.1 (Patient Support Programs), 14.2.2 (Ensure integrity of the industry), and 14.2.3 (Conflict of Interest) of the Innovative Medicines Canada Code of Ethical Practices (the “Code”).
Status: No Infraction
Breach: No Breach
Complaint Completed: December 20, 2016
Company X vs Company Y
Summary: Company X alleged that Company Y induced a group purchasing organization’s members’ physicians by providing inappropriate incentives as part of signing a purchasing agreement in contravention of guiding principle #8 and section 12.2.4.
Status: No Infraction
Breach: No Breach
Appeal: No Appeal
Complaint Completed: April 2, 2015
There were no IPRC decisions for this year.
There were no IPRC decisions for this year.
Individual X, Patient Group Member vs. Company Y
Summary: Complainant alleged that Company Y engaged in disguised marketing to patient group members in contravention of Section 12 (Market Research) of the Code of Ethical Practices.
Status: No Infraction
Breach: No Breach
Appeal: No Appeal
Complaint Completed: March 20, 2012
Purdue Pharma vs. Janssen
Summary: Allegation that the Janssen voucher program re:
Nucynta Cr and Jurnista (the Janssen voucher program) violates Guiding Principle 1 of the Rx&D Code of Ethical Practices (Code). Guided by the Appeal Panel decision (Purdue Pharma vs. Mr. Ken Burns, Pharmacist) the Industry Practices Review Committee (IPRC) determined that the Janssen voucher program contravenes Guiding Principle 1 of the Code.
Breach: Guiding Principle # 1
Appeal: No Appeal
Complaint Completed: October 20, 2011
Status: Infraction
Company X (non-member) v. Company Y Inc. re: Product Z (generic)
Summary: That Company Y violated the Code of Ethical Practices in connection to its campaign (Study 123) to create the false impression among Canadian Health Care Professionals that generic Product Z is less safe, less pure and less effective than its brand Product A.
Breach: No Breach
Appeal: No Appeal
Complaint Completed: October 20, 2011Status: No infraction
Company X vs. Company Y
Complaint Withdrawn: the complaint was to have been heard and adjudicated by the IPRC. However, before the meeting Rx&D received a written notification from Company Y withdrawing the complaint. Therefore, the matter was not discussed by the IPRC and Rx&D has closed the file.
Breach: No Breach
Appeal: No appeal
Complaint Completed:
September 8, 2010
Status: Complaint withdrawn
Servier Canada Inc. vs. Mr. Gabriel Baddour, Pharmacist
Summary: Allegation that a Servier sales representative made inappropriate comments regarding potential safety concerns associated with prescribing a generic competitor. The IPRC believes that one or more violations of Section 8 (Role of the Representative) have occurred.
Breach: Breaches section 8
Appeal: No appeal
Complaint Completed: September 8, 2010
Status: Infraction
Company X vs. HCP Y
Summary: Allegation that Company X was promoting a drug for a use that is not stated on the Product Monograph and this in turn contravenes a guiding principle of the Code.
Breach: No Breach
Appeal: No appeal
Complaint Completed:
April 28, 2010
Status: No infraction
Our e-Learning program was created in response to our members’ desire to understand and comply with the code and pharmaceutical industry regulations.
As part of our commitment to high ethical standards and enhancing trust, Innovative Medicines Canada has developed a Voluntary Framework on Disclosure of Payments made to healthcare professionals and organizations in exchange for services, and to fund charitable, educational and scientific activities.
Collaboration between healthcare professionals, healthcare organizations and the pharmaceutical industry is essential to improving the quality of life of Canadians, as such collaboration drives scientific advancements, enhances medical education and promotes health literacy.
Starting in June 2017, 10 Canadian pharmaceutical companies – all of them members of Innovative Medicines Canada – will begin publishing aggregated sums of their payments to Canadian healthcare professionals (HCPs) and healthcare organizations (HCOs) based on the following reporting framework:
There are currently 10 voluntary disclosing member companies:
The Voluntary Framework on Disclosure of Payments provides members of Innovative Medicines Canada with a framework to publish aggregated sums of payments to Canadian healthcare professionals (HCPs) and healthcare organizations (HCOs).
IMC considered the types of activities and categories where member companies would disclose aggregated payments. We decided that disclosure would take place in the following areas:
This applies to any direct or indirect payment made to a Canadian HCP by a Canadian Innovative Medicines Canada member company, or third party acting on behalf of the member company, in exchange for services rendered by the HCP to the Canadian member company. Services may include those rendered as a speaker, consultant or advisor to the Canadian member company.
Consistent with the current Code of Ethical Practices, an HCP is defined as, “… a person who by education, training, certification, or licensure is qualified to and is engaged in providing healthcare. This can include any of the following: an individual who is currently practicing medicine, nursing, or dispensing medicines in Canada or any other person who, in the course of his or her professional activities, may prescribe, recommend, or administer a prescription medicine or be involved in related treatment or disease management.”
For greater certainty, a direct or indirect payment to a Canadian HCP payment is defined as:
Member companies should be prepared to disclose the aggregated totals of fee for service. Depending on the member company’s system and reporting capabilities, these totals may or may not include applicable taxes as well as related incidental expenses.
Member companies are encouraged to include explanatory notes on their respective websites to describe and explain the amounts disclosed. For instance, a member company whose systems do not allow the extraction of applicable taxes may include an explanatory note to the effect of, “*taxes included.” Payments made for services, as defined here, rendered by a Canadian HCP for an international affiliate of the Canadian member company, would not be considered in scope for this framework.
This applies to direct or indirect provision of funding to an HCO for the purpose of supporting efforts related to, but not limited to, charitable, educational and scientific activities. For the purpose of this framework, an HCO is defined as a private or public sector organization, institution or association that is composed of HCPs and/or provides healthcare services (e.g. hospitals, primary care organizations, hospital foundations, HCP organizations and universities).
This provision of funding excludes:
This applies to a direct or indirect provision of financial assistance to a Canadian HCP for the purpose of attending an international congress (as permitted under section 10.2 of the Code of Ethical Practices). Such funding is intended for expenses related to travel, accommodation, meals and congress registration fees (as permitted by the Code) and does not include any honoraria or fee for service.
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