Responsible Promotion Activities

Basic approach

Our vision of our sales activities is to work as a team, think from the patient's perspective, and respond to the real needs of healthcare professionals, based on the belief of "Contribute to patients’ wellbeing as a true medical partner”. As a life-related company, we always maintain high ethical standards. In order to provide appropriate information on pharmaceutical drugs, the Sales and Marketing department and each department (Risk&Compliance Management Department, Safety and Quality Assurance, etc.) collaborate to promote responsible promotion activities. We pursue promotion activities in accordance with the “ONO Pharmaceutical Code of Practice (hereinafter the “Code”)”, which has been formulated as our corporate action guidelines in compliance with the JPMA Code of Practice.

Pursuit of fair promotion activities

We define "Promotions” as "Providing and transmitting drug information to healthcare professionals and promote the proper use and spread of ethical drugs based on such information”. All employees involved in promotion carry out fair promotion activities, while always examining whether they are acting in accordance with the spirit of the Code regardless of whether there are specific provisions or descriptions in the Code. Furthermore, based on the Code, we not only comply with the “Guidelines on Activities to Provide Sales Information on Prescription Drugs” (hereinafter the “Guidelines”) issued by the Ministry of Health, Labour and Welfare of Japan, and the “Promotion Code for Prescription Drugs” established by the Japan Pharmaceutical Manufacturers Association (JPMA), but also respect the IFPMA (International Federation of Pharmaceutical Manufacturers & Associations) Code of Practice.

Management system for promotion activities

We have established a Sales Information Activities Supervisory Division within the Risk & Compliance Management Department as a system for guiding and supervising fair promotional activities. This division constantly checks that promotional activities are being conducted appropriately by carrying out three actions, namely, examining promotional materials (including lecture slides), monitoring the promotional activities themselves (business records as described by MRs), and conducting education and training on a regular basis. We have also established an Examination and Supervision Committee that includes external third parties, and we receive advice from this committee on our sales information provision activities. In addition, the Internal Audit Department conducts internal audits every year to confirm compliance with this Code, as well as with internal rules and regulations. In the event that an inappropriate promotional activity does occur, we will promptly collect and investigate information regarding the incident before requiring the Sales Information Activities Division to take corrective action and preventative measures.

Review system for promotional materials

In promotion, the provision of accurate information is required to promote the proper use and spread of pharmaceuticals. All materials used for promotion undergo a review process by the Sales Information Activities Supervisory Division, which involves a review by external third parties.
We also strive to provide appropriate information on slides used by speakers in sponsored and co-hosted lecture meetings, by checking in advance whether the Sales Information Activities Supervisory Division contains any unapproved information on pharmaceuticals. The Sales Information Activities Division is not involved in any of these processes.

Training for thorough implementation of fair promotion activities

We provide training for all employees involved in promotion activities to enhance their awareness of compliance. Specifically, every year, we set up a Compliance Promotion Month (three months) to raise awareness of compliance in general, and the Risk&Compliance Management Department provides training for branches and sales offices twice a year. Training on guidelines for sales information provision activities is conducted once a year for employees involved in promotion, including executives. Furthermore, we organize lecture training sessions given by the leaders of various departments as well as e-learning training courses in order to improve employees’ knowledge and understanding of compliance in general. In the event of a violation of the Code, we promptly conduct special training sessions on a company-wide scale to prevent the occurrence and recurrence of violations.

  Frequency Scope Main contents
Training by Risk&Compliance Management Department Twice a year Code, Guidelines, Fair Competition Code Operating rules of lectures hosted and co-hosted by our company, Appropriate promotional activities
Training by leaders in departments Twice a year Guidelines Appropriate provision of information (Company Records)
Rules for lectures hosted by our company (Prior confirmation of slides)
Training by e-learning Once a month Code, Guidelines, Fair Competition Code Q&A for Code and guideline compliance

Training for promoting proper use of pharmaceuticals and collecting safety information

In promotion activities, it is important to quickly collect safety information on prescribed drugs and provide appropriate information, based on collected information, to healthcare professionals to further promote proper use of pharmaceuticals. We conduct introductory training on "Ministerial Ordinance on the Post-Marketing Safety Management of Drugs (GVP Ordinance)" in a lecture format for all employees involved in promotion activities. After that, training on drug risk management plans (RMP) is also conducted at the launch of a new product and once a year, and training on pharmaceutical damage is conducted every two years. In addition, continuing education on the collection of post-marketing safety information is conducted every year.
All employees involved in promotion activities are fully aware of safety characteristics of each drug as well as the importance of safety management, and promote the proper use of drugs and collect safety information in order to minimize the occurrence of side effects in patients.