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.
Complaints must be submitted in writing and sent to Innovative Medicines Canada by mail or email to the addresses below for tracking purposes. Verbal, telephone or fax complaints will not be accepted. All complaints should be addressed to:
Attention: Industry Practices Review Committee c/o Executive Director, Ethics, Legal and Regulatory, Innovative Medicines Canada, 55 rue Metcalfe Street, Suite 1220, Ottawa, ON K1P 6L5 You may also send your complaints to the following email address: complaints@imc-mnc.ca
Complaints must specify the Innovative Medicines Canada member company against which the complaint is being made. Complainants are advised that the Code of Ethical Practices applies to Innovative Medicines Canada members. It does not apply to generic drug companies, or to innovative pharmaceutical companies that are not members of Innovative Medicines Canada. A list of member companies is available on Innovative Medicines Canada’s website at: https://innovativemedicines.ca/about/member-companies/
Complainant Identity and Contact Information. Each complainant must identify him or herself, and any company/organization/association with which they are affiliated. Full return address and contact information must also be provided. Anonymous complaints or complaints with inadequate complainant contact information will not be considered. Unless the complainant has identified him or herself to the member company that is the subject of the complaint, Innovative Medicines Canada will not identify the complainant to the member company during the investigation and adjudication process. Member companies that are complainants are encouraged to identify themselves. However, complainants are hereby notified that in the event that a Code complaint decision of the Industry Practices Review Committee (IPRC) is appealed (by either the complainant or the member company, and unless the complainant chooses to discontinue the complaint upon appeal by the member company), the complainant’s identity will be disclosed, and the complainant will be required to participate in the arbitration process.
Complainants must set out in writing as much specific information as possible (who/what/when/where) regarding their complaint. Evidence in the form of documentation and/or photographs is permissible, but complainants are advised that Innovative Medicines Canada may not return any materials submitted. Complainants are advised that the provision of timely, clear and accurate information will greatly assist in the processing of the complaint. Complaints regarding potential Code breaches that are determined to have occurred more than one hundred and twenty (120) days after the event(s) giving rise to the complaint(s) became known to, or reasonably ought to have been known to, the complainant, will not be considered by the IPRC.
If possible, complainants should set out what section(s) of the Code of Ethical Practices the complainant believes has been violated. Correct references to the Code will facilitate the processing of a complaint.
Before the complaint is formally reviewed by the IPRC and without prejudice to the complaint, Innovative Medicines Canada will attempt to engage the disputing parties in an initial exchange of information. This normally involves Innovative Medicines Canada seeking a timely written response to the complaint by the Member that is subject to the complaint. Subject to the Member’s agreement, this response will be shared with the complainant. If the complainant wishes to withdraw the complaint, the complaint process is terminated at this point. A letter confirming that the file has been closed will be sent from Innovative Medicines Canada to both parties. Otherwise, Innovative Medicines Canada will refer the complaint file to the IPRC for adjudication.
Complainants should also be aware that in order to process and adjudicate the complaint, follow-up enquiries from Innovative Medicines Canada may be required. Failure to respond to such enquiries may result in the discontinuation of the complaint process.
Complaints regarding member company advertising issues should not be directed to Innovative Medicines Canada, but rather should be directed to the Pharmaceutical Advertising Advisory Board (PAAB) at:
Pharmaceutical Advertising Advisory Board
300 – 1305 Pickering Parkway
Pickering, ON
LIV 3P2
Complainants may submit complaints in accordance with these requirements in English or in French.
The Code of Ethical Practices 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 the volunteer members may preclude strict compliance. In an effort to minimize possible scheduling conflicts between the members, the IPRC will pre-schedule at least four (4) meetings throughout the year. The 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 wishes to ensure that all complaints submitted in accordance with this process have been filed by the complainant in good faith. Innovative Medicines Canada reserves the right to reject complaints that are determined to be frivolous, vexatious, and abusive to Innovative Medicines Canada and/or its member companies, moot, or otherwise made in bad faith.
Innovative Medicines Canada encourages transparency, especially in relation to its Code of Ethical Practices. To that end, 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’ website. Only on the occasions where the IPRC determines an infraction will the Member’s name be published on the Members’ website.
NOTE: In the event that any of the following complaint requirements are not followed, complainants are advised that Innovative Medicines Canada reserves the right to reject their complaint without further notice
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.
In June 2017, Innovative Medicines Canada developed a framework to support member companies who choose to publish aggregated sums of payments to Canadian healthcare professionals (HCPs) and healthcare organizations (HCOs) based on the following reporting framework:
At that time, there were 10 companies who voluntarily disclosed payments:
Innovative Medicines Canada does not collect any payment information from members. Member companies who continue to voluntarily disclose payment information publish directly to their own websites.
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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