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The International Comparative Legal Guide to:
Pharmaceutical Advertising 2012
9th Edition
A practical cross-border insight into pharmaceutical advertising
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Clifford Chance
CMS
Davis LLP
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Nishimura & Asahi
Olivares & Cia., S.C.
PDG Avocats
Roschier, Attorneys Ltd.
Schellenberg Wittmer
Sidley Austin LLP
Sołtysiński Kawecki & Szlęzak
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The International Comparative Legal Guide to: Pharmaceutical Advertising 2012
Preface:
Preface by Tom Spencer, Counsel, GlaxoSmithKline Plc.
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General Chapters:
1 The European Commission’s Proposal on Providing Information to the General Public on
Prescription-Only Medicinal Products - Jackie Mulryne & Silvia Valverde,
Arnold & Porter (UK) LLP 1
2 Pharmaceutical Promotion and the UK Bribery Act - Alison Dennis & Tony Lewis,
Field Fisher Waterhouse LLP 8
Country Question and Answer Chapters:
3 Australia Clayton Utz: Colin Loveday & Greg Williams 13
4 Austria Herbst Kinsky Rechtsanwälte GmbH: Dr Sonja Hebenstreit &
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5 Belgium Allen & Overy LLP: Geert Glas & Dieter Delarue 34
6 Brazil Licks Advogados: Otto Licks 44
7 Bulgaria CMS Cameron McKenna: David Butts & Angelika Dimitrova 51
8 Canada Davis LLP: Bill Hearn & Samuel Schwartz 61
9 Czech Republic CMS Cameron McKenna: Denisa Assefová & Vladěna Kuřecová 74
10 Denmark Jusmedico Advokatanpartsselskab: Jan Bjerrum Bach & Lone Hertz 82
11 England & Wales Arnold & Porter (UK) LLP: Silvia Valverde & Ewan Townsend 95
12 Finland Roschier, Attorneys Ltd.: Mikael Segercrantz & Johanna Lilja 108
13 France PDG Avocats: Paule Drouault-Gardrat & Juliette Peterka 118
14 Germany Clifford Chance: Dr Peter Dieners & Marc Oeben 125
15 Hungary CMS Cameron McKenna: Dóra Petrányi & Veronika Bednár 137
16 Ireland Arthur Cox: Declan Hayes & Colin Kavanagh 146
17 Italy Biolato Longo Ridola & Mori: Linda Longo & Andrea Moretti 155
18 Japan Nishimura & Asahi: Somuku Iimura & Yoko Kasai 166
19 Korea Hwang Mok Park P.C.: Kun Su Mok & Hye Yeon Lim 175
20 Malta Ganado & Associates, Advocates: Dr. Anthony Cremona & Thomas Cutts-Watson 183
21 Mexico Olivares & Cia., S.C.: Alejandro Luna & Juan Luis Serrano 195
22 Netherlands Life Sciences Legal Advocaten: Anke E. Heezius 204
23 Norway Advokatfirmaet Grette DA: Felix Reimers & Erik Helstad 212
24 Poland Sołtysiński Kawecki & Szlęzak: Dr. Ewa Skrzydło-Tefelska &
Agnieszka Jurcewicz 222
25 Portugal Vieira de Almeida & Associados: Paulo Pinheiro & Francisca Paulouro 229
26 Romania CMS Cameron McKenna: Valentina Parvu & Ioana Oprea-Barac 238
27 Russia CMS, Russia: Vsevolod Tyupa 247
28 Slovenia Avbreht, Zajc & Partners Ltd.: Andrej Kirm 254
29 South Africa Adams & Adams: Alexis Apostolidis & Pieter Visagie 263
30 Spain Faus & Moliner: Jordi Faus & Rodrigo Osorio 271
31 Sweden Mannheimer Swartling Advokatbyrå: Helén Waxberg & Fredrik Lundegårdh 281
32 Switzerland Schellenberg Wittmer: Andrea Mondini & Christine Beusch-Liggenstorfer 290
33 Turkey YükselKarkınKüçük Attorney Partnership: Gökhan Gökçe & İrem Cansu Atikcan 301
34 Ukraine Arzinger: Timur Bondaryev & Svitlana Postrygan 310
35 USA Sidley Austin LLP: Coleen Klasmeier & Maura Norden 320
36 Vietnam Tilleke & Gibbins: Tu Ngoc Trinh & Dzung Thi Thuy Nguyen 339
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Chapter 2
Pharmaceutical
Promotion and the
UK Bribery Act
Field Fisher Waterhouse LLP
Alison Dennis
Tony Lewis
8
The Bribery Act came into force on 1 July 2011. Together with
explanatory guidance published by the Ministry of Justice in March
2011, the new law replaced the outdated UK anti-bribery legislation
which was over 100 years old. The UK was required to implement
modern anti-bribery legislation by the OECD Convention it ratified
in 1999. However, the 2002 enactments by the UK did not to fully
achieve this goal and the UK was recognised to have failed to meet
its obligations until enactment of the 2010 Bribery Act.
The pharmaceutical industry has for many years taken a battering
particularly from the US authorities over bribery and kick-backs
and has paid some very substantial fines for breaches of anticorruption
legislation, both in the US and elsewhere. For this
reason, the pharmaceutical industry has had the opportunity to
consider, in advance, some other industries which behaviours
constitute bribery and which are acceptable ways of doing business.
This detailed consideration of the ethics of selling pharmaceutical
products has brought into existence various industry codes of
practice, such as those published by IFPMA, EFPIA, PhRMA and
ABPI, as well as equivalent codes in the medical devices industry:
EUCOMED; Advamed; and ABHI. Each of these codes define, in
some cases in substantial detail, the promotional activities (as well
as other activities) which are considered by the industries to be
acceptable because they are deemed not to influence the prescribing
habits of medical professionals. The UK’s Serious Fraud Office
(SFO) has indicated that compliance with an industry code might be
evidence that no bribery has taken place, but that this compliance is
not a cast-iron guarantee that the activity will not be scrutinised and
even prosecuted.
This chapter considers whether the promotional activities of
pharmaceutical companies might breach the rules under the Bribery
Act, with a view also of the guidance issued by the Ministry of
Justice. We also look at the ABPI code (as one of the most detailed
industry codes) and consider whether there are any potential
conflicts between the activities which are permitted by the ABPI
code and those which might breach the Bribery Act 2010. We also
consider the extensive extraterritorial jurisdiction engaged by the
Bribery Act and how this might apply to promotion activities
engaged in by global pharmaceutical companies.
As a note of caution, it must be remembered that industry codes on
promotional activities are limited in scope. There are many other
activities engaged in by pharmaceutical companies which might
breach anti-corruption laws. Meeting the requirements of these
codes and laws are therefore only a part of any compliance
programme. Conversely, promotional activities which do not
involve the provision of a benefit to a third party, whether a gift,
benefit in kind or pecuniary advantage, will not breach anti-bribery
legislation, but could breach an industry code.
Promotional Activities and Bribery Act Offences
There are potentially three separate Bribery Act offences which
might be committed through promotional activities.
Inducement of Improper Performance
Promotional activities which involve the provision of inducements
in exchange for doctors or administrators prescribing or purchasing
particular products might amount to an offence under the Bribery
Act 2010, Section 1, because in each case, the company will be
offering or giving an advantage intended to induce a person to, or
reward a person for, improper performance, with that “improper
performance” being specified by codes and laws which are
applicable to the person accepting the inducement.
The GMC guide on Good Medical Practice states that UK
registered doctors “must act in your patients’ best interests when
making referrals and when providing or arranging treatment or care.
You must not ask for or accept any inducement, gift or hospitality
which may affect or be seen to affect the way you prescribe for,
treat, or refer patients”. Likewise, under the NHS rules on The
Code of Conduct for NHS Managers (2002) managers making
purchasing decisions about pharmaceuticals are required to ensure
that decisions are not improperly influenced by gifts or
inducements. Most countries in the developed world will have
similar deontological codes for their physicians and administrators
and some countries will have these included as part of their laws on
pharmaceutical promotion. As is discussed later in this chapter, the
Bribery Act is not limited jurisdictionally to activities taking place
in the UK. A failure of a pharmaceutical company to meet the
requirements of these foreign codes or laws might, if bribery is
proven and the company has the required nexus with the UK,
constitute a breach of the Bribery Act.
The Bribery Act also requires that the physician or administrator is
under an obligation in their “function or activity” to prescribe or
purchase “in good faith, or impartially” or alternatively that they are
in a position of trust in their performance of it. Arguably, all three
of these conditions might apply to their engagement in the selection
of pharmaceutical products for prescription and/or purchase.
Bribery of Foreign Public Officials
Whilst the ABPI code will generally not apply to promotional
activities addressed to physicians and hospital managers based
outside the UK, the Bribery Act has the potential to do so. Section
6 of the Act prohibits bribing a foreign public official with an
intention to influence that individual in that capacity, but also with
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Field Fisher Waterhouse LLP
Pharmaceutical Promotion and the UK Bribery Act
an intention to obtain or retain business or an advantage in the
conduct of business. In most countries in Europe, and in many
other countries world-wide, hospitals are run by the state and
therefore both the doctors and administrators will, in these
hospitals, be “foreign public officials”. There is therefore potential
for promotional activities addressed to such individuals, if they
constitute a “bribe”, to breach section 6.
Failure to Prevent Bribery
This offence is only applicable to commercial organisations and not
to individuals. It is committed if a person “associated” with the
company is engaged in bribery for the benefit of the company. No
particular knowledge or acquiescence is required for the offence to
have been committed and this offence is therefore often referred to
as the “strict liability” offence.
The proximity of the person engaging in the bribery to the person
who might be liable for it has been the subject of much speculation.
Promotional activities might of course be undertaken by a whole
range of persons on behalf of a company, particularly when selling
overseas or in jurisdictions which are less friendly towards foreign
companies and require the use of local intermediaries to broker the
sales. In these countries the question is particularly pertinent.
The Ministry of Justice guidance does give some clarification on
the point. The guidance states that an employee of the company is
presumed to be performing services for the company, and agents
and subsidiaries could be performing services. Furthermore “all
relevant circumstances” are to be considered when deciding
whether the relationship between a company and a third party will
make that third party an “associated person” for which the company
is responsible under the Act. The Guidance rather unhelpfully
states that the definition is deliberately large “to embrace the whole
range of persons connected to an organisation who might be
capable of committing bribery on the organisation’s behalf”. The
words “on the organisation’s behalf” would seem to indicate that a
distributor who sells for their own account would not be an
“associated person”. However, there are further examples given in
the guidance where a purchaser of goods is performing services for
the original manufacturer and not just acting as an onward seller of
those goods for their own account. In the pharmaceutical industry,
the relationship between a company and those purchasing and
selling its products is often a close one because of the need for
continuous pharmacovigilance, traceability and the ability to
undertake recalls. The guidance does go on to say that a company
is “likely only to exercise control over its relationship with its
contractual counterparty” and not further down the supply chain.
However, if pharmacovigilance and traceability requirements
necessitate a close relationship with those further down the supply
chain, it is perhaps possible that the pharmaceutical industry is the
one which might be the exception as the use of the word “likely”
perhaps indicates that there will be some exceptions?
If a company is found guilty of the corporate offence of failing to
prevent bribery, its liability is unlimited. An additional concern is
that in the European Union, any company found guilty of bribery
anywhere in the world, may be barred from future government
contracts in all twenty-seven Member States. This in some ways
seems to be a particularly harsh penalty for promotional activities
which have overstepped the boundaries.
There is a defence to this strict liability corporate offence if the
company can show that it has “adequate procedures” in place
designed to prevent “persons associated with [the company] from
undertaking such conduct”. This will mean that a pharmaceutical
company’s own code for compliance, as well as its implementation
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will in the future have a dual role: firstly to achieve compliance
with applicable laws and rules; and secondly to contribute to
“adequate procedures” and as such the “get out of jail free card”
with respect to the Bribery Act. This defence will of course only be
used after an actual act of bribery has been committed. Once a
company is found to have dirty hands it will neither be easy nor
straightforward for them to prove that it was not their “fault” or that
they did all they could to keep them clean.
Particular Promotional Activities and the Bribery
Act
Promotional Aids
The ABPI 2011 Code, which was fully effective from 1 May 2011, has
introduced a rule about promotional aids which is new to the UK.
Pharmaceutical companies are no longer permitted to provide
promotional aids which previously habitually included stationery
items, such as computer accessories for business use, pens, pads,
diaries and calendars and clinical items, such as nail brushes, surgical
gloves, tongue depressors, tissues and peak flow metres. The previous
rule permitted these gifts if they were less than £6 in value, and names
of medicines could be included on them if this would not be
misleading. This change brings the UK into line with both PhARMA
and Advamed on this particular point. It also shows a changing
“ethic”, which is something that we discuss further below. It was
previously considered that the giving of such items would not affect
the integrity of doctors. Some psychology studies have shown that a
person receiving a gift or benefit, however trivial, generally feels a
sense of obligation to the giver. There was also, in this case the
subliminal value of a particular medicine’s name being visible in a
physician’s practice every day. These are perhaps the reasons for the
change both in the US and subsequently the UK. It is unlikely that the
SFO will want to concern itself with gifts under £6 when there are
rather more substantial bribes to consider. However, this seemingly
trivial change in the ABPI Code has also changed the way in which
such gifts, when given in the UK by a company which has signed up
to the ABPI Code, might be treated under the Bribery Act. Under
Section 1 of the Bribery Act, it would have been argued that under the
2008 version of the ABPI Code that the giving of such gifts did not
constitute “improper performance” because it was considered that
they did not have the effect of inducing anyone to prescribe a medicine
where they would not otherwise have done so. From the effective date
of the 2011 version of the ABPI Code, the £6 promotional item is
deemed to have such an effect on the doctor, essentially changing the
nature of the action from not being a “bribe” to actually being a bribe.
Medical and Educational Goods
Under the ABPI Code, individual companies are permitted to supply
medical and educational goods and services as long as these are for the
benefit of patients or the NHS and are not provided to individuals for
their personal benefit. Medical and educational goods provided in this
way may bear the name of the company, but not of a particular
medicine. There is a long list of additional rules in an attempt to create
a barrier between the sale and prescription of medicines and the
provision of goods or services. However, the provision of goods and
services provides pharmaceutical companies with a means of
strengthening their links with the people who are, in effect, their
“customers”. Given the strong financial incentives for pharmaceutical
companies to do this, might this be another area in which the “ethics”
of such gifts might in future be the subject of a seismic ethical shift in
the same way that promotional aids have been?
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9

Field Fisher Waterhouse LLP
Pharmaceutical Promotion and the UK Bribery Act
Meetings and Hospitality
Meetings with healthcare professionals, hospital administrators and
other persons making decisions on the use and purchase of
pharmaceutical products are not, of themselves, problematic under
the Bribery Act. However, once “hospitality” is added to the
agenda for such meetings or gifts beyond pens, pencils and paper
necessary for the meeting (without the name of a particular
medicine inscribed on them), that is where a concern is raised under
the code, and as a result of this, under the Bribery Act.
In the guidance under Section 1, an example given of the permitted
hospitality is taking foreign clients to a six nations match at
Twickenham “to cement good relations or enhance knowledge in
the organisation’s field”. However, taking a doctor or hospital
administrator would constitute a breach of the GMC Code of Good
Practice and also likely the administrator’s own employee code,
either NHS or private. As such, this would constitute improper
performance of a relevant function or activity. Where prescribers or
purchasers of pharmaceuticals are involved, anything which goes
beyond meeting the basic human need to eat regularly (but not
lavishly) and where the timing of a meeting necessitates it, needs to
be given some thought. This illustrates the point that the
pharmaceutical industry should not slavishly read the guidance to
the Bribery Act as if it is wholly applicable to its activities: this
industry has a different set of ethics because of the ethical
imperative that patients should receive the most appropriate
treatment.
Charity Donations
Physicians sometimes request donations for medical charities. The
ABPI Code states that modest payments into a reputable charity are
acceptable if they are not an “inducement”. The ABPI Code does
not go into detail on what might constitute an “inducement”. There
are, however, situations where a physician has a close personal
connection with a charity, including where it funds their own
research, which might include part of their salary and/or a salary for
their own researchers. This question arises frequently in the
medical devices industry where, as a matter of necessity, the
industry works closely with physicians in the development of new
or improved devices. The EUCOMED Code is therefore more
detailed on this point. The EUCOMED Code requires that “a
written request should be submitted by the charitable organisation,
detailing the purpose of the charity and the nature of its activities.
The payment should be made out in the name of the charity and
paid directly to the charity. Charitable donations to a bona fide
organisation should not be made in response to requests made by
Health Care Professionals unless the Health Care Professional is an
employee or officer of the organisation and submits the request on
behalf of the organisation.” This illustrates the need to undertake
an individual analysis of the situation of the physician, their
relationship with the company and the charity and the precise
destination and beneficiary of the monies. The particular point to
answer is whether the donation is “bona fide”, or if there is an
intention to benefit an individual, even if it is not a direct personal
financial benefit, but one which might act as a perceived
inducement to prescribe?
Promotional Activities Through Tenders
Where tenders are offered, it is common for goods or services to be
requested and/or offered which extend beyond the goods which are
the main subject of the tender. An example in this industry might
be a diabetes nurse. However, European law requires that the items
or services which are not the main subject matter of the
procurement do not influence the final outcome of the procurement
process. Therefore, offering these additional goods or services will
only be an offence if they influence the final outcome. This is not
something a company might know in advance of the final decision
of the tendering authorities, and even then is something they might
have to imply. The Bribery Act guidance goes on to state that
“prosecutors will consider the public interest in prosecuting” and in
these circumstances pharmaceutical companies might want to
determine, in advance of engaging in such processes, whether they
are comfortable being “under consideration” by the prosecuting
authorities, or whether they would prefer to avoid this scrutiny by
not offering these additional items or services at all. Government
tenders in the UK frequently specifically include a request for these
additional goods and services. This is unlikely to change unless all
pharmaceutical companies refuse to offer them.
Jurisdictional Scope of the Bribery Act and the
Promotional Activities:
Examples given above illustrate how activities categorised as
“promotion” might be problematic under the Bribery Act. We have
looked at the ABPI Code for the purposes of this illustration.
However, like the US Foreign Corrupt Practices Act, the territorial
reach of the Act is extensive and goes way beyond activities taking
place in the UK. Pharmaceutical companies, wherever they are
incorporated, may be liable for actual acts of bribery if acts or
omissions forming part of the offence (meaning bribery or bribing
a foreign public official) occur in the UK. If the same acts or
omissions occur outside the UK, then the UK courts will have
jurisdiction over corporate bodies only if they are incorporated in
the UK.
However, of greatest concern to pharmaceutical companies with a
global footprint is the offence of failing to prevent bribery. The act
or omission constituting bribery can have occurred anywhere in the
world, and the failure to prevent it might be committed by a
company that carries on a “business”, or only “part of a business”,
in the UK. In the promotion of pharmaceutical products in different
countries a variety of corporate structures are used. It would appear
from the way the Bribery Act is written that it is not necessary for a
company to even have a subsidiary in the UK for there to be a
sufficient nexus for the offence to have been committed and
prosecuted. Just having a sales office or representative in the UK
might suffice to bring a pharmaceutical company with its
headquarters outside the UK within the jurisdiction of the UK
courts for the purposes of the Act, even for activities carried on in
another separate country.
In addition to this corporate liability, individual directors and
managers who are “senior officers” of global pharmaceutical
companies might personally be prosecuted under the Bribery Act.
These individuals need personally to have a “close connection” to
the UK where “close connection” essentially means that the
individual has British citizenship or residency, or is a national of a
British overseas territory. Their personal responsibility would arise
if promotional activities of the company amounting to the offence
of bribery or bribery of any foreign public official were ones to
which they consented or in which they have connived. Individuals
convicted under the Act can be imprisoned for up to ten years.
10
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Field Fisher Waterhouse LLP
Pharmaceutical Promotion and the UK Bribery Act
Failure to Prevent Bribery: Relevant Commercial
Organisation
The “strict liability” corporate offence of “failure to prevent
bribery” applies to any “relevant commercial organisation”. The
definition of a “relevant commercial organisation” potentially
includes pharmaceutical companies which might have only limited
connection to the UK, but which promote their products worldwide.
This limited connection requires only that the company “carries on
a business or part of a business, in any part of the UK”. The
guidance states that the government expects that a “common sense
approach” will be applied. Given the vagueness of this direction,
we do not yet have sufficient information to know whether having
a mere sales office in the UK will be sufficient to allow the SFO to
prosecute a company for its promotional activities occurring in
other jurisdictions. The guidance states that any “commercial
activities” will constitute carrying on a business but that having a
UK subsidiary will not, itself, mean that a parent company is
carrying on a business in the UK, since a subsidiary “may act
independently of its parent or other group companies”. If a
pharmaceutical company might be responsible for an independent
third party distributor, because of the nexus through
pharmacovigilance activities, it is difficult to see how it would not
also be responsible for its own subsidiary or branch office
undertaking similar activities, but actually on behalf of the
corporate group. Whilst the Guidance (but not the Act) seems to be
clear that a parent company will not always be held to be
responsible for the bribery of its subsidiaries, it is difficult to
imagine that a parent company will escape liability for a UK
subsidiary wherever in the world it might be undertaking those
promotional activities.
We will, however, have to see whether the SFO will flex its muscles
only if a UK parent has had some direct involvement in the bribery
(for example, through their management or direction), or whether
they will be considered de facto to have failed to prevent bribery
simply because the bribery has been engaged in by a subsidiary
over which it ought to have exerted control.
Conclusion
Whilst the pharmaceutical industry is ahead of other industries in
terms of having already considered in some detail which of its
activities might potentially amount to improper inducements, it is
possible that as a result of the Bribery Act, some of the activities
which are currently “permitted” through industry codes might need
to be reassessed. This article also illustrates the fact that
generalised statements in the guidance issued by the Ministry of
Justice should be read caution when trying to apply the guidance to
the promotional activities of the pharmaceutical industry because of
the different ethic applicable to the sale and marketing of
pharmaceuticals when compared with other unregulated products.
Global pharmaceutical companies might also want to consider
carefully the location of their subsidiaries, branches and sales
offices and what the reporting lines are between them. From this
they will be able to determine where there is potential for the
Bribery Act to apply, particularly where their senior managers are
UK residents or citizens and who, as a result, will have a connection
to the UK for individual liability no matter where in the world they
carry out their duties.
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11

Field Fisher Waterhouse LLP
Pharmaceutical Promotion and the UK Bribery Act
Alison Dennis
Field Fisher Waterhouse LLP
35 Vine Street
London, EC3N 2PX
United Kingdom
Tel: +44 20 7861 4637
Fax: +44 20 7488 0084
Email: alison.dennis@ffw.com
URL: www.ffw.com
Tony Lewis
Field Fisher Waterhouse LLP
35 Vine Street
London, EC3N 2PX
United Kingdom
Tel: +44 20 7861 4940
Fax: +44 20 7488 0084
Email: tony.lewis@ffw.com
URL: www.ffw.com
Alison is a Partner and head of Life Sciences for Field Fisher
Waterhouse LLP. She works with clients in the pharmaceutical,
biotech. and medical device industries from across the globe.
Alison helps clients in these industries to resolve regulatory
issues and to comply with laws and codes on advertising and
promotion. In addition, Alison uses her extensive transactional
experience in drafting and negotiating a wide range of specialist
agreements for clients in the Life Sciences sector, with particular
emphasis on the protection and exploitation of intellectual
property rights through a variety of different structures.
Alison is a graduate of the Universities of Bristol and Oxford and
is a fluent French speaker.
Alison sits on both the Legal Committee and the Compliance
Working Group of the ABHI (UK trade association for medical
devices industry).
Tony is head of the Fraud and Anti-Corruption team at Field
Fisher Waterhouse LLP. He is a recognised as an expert in the
legal directories, specialising in investigations and claims arising
from fraudulent conduct, focussing on corruption, tracing assets,
theft of confidential information and other assets, money
laundering, and the interplay between civil and criminal
proceedings. Tony has acted in many high profile, complex and
reported cases, often multi-jurisdictional. He is at the forefront of
developments relating to the Bribery Act 2010, having contributed
to the consultation process that proceeded the legislation, and
having spoken and written extensively on the topic.
Tony is also an active member of various professional
organisations, including the Commercial Fraud Lawyers’
Association, the International Bar Association, the London Fraud
Forum, the Commercial Litigators’ Forum and the Proceeds of
Crime Lawyers’ Association.
Field Fisher Waterhouse is a European law firm specialising in providing commercial solutions for all industries and sectors. We
have a particular focus on companies that are highly regulated and those with intellectual property and technology driven business
models. We have offices in Brussels, Düsseldorf, Hamburg, London, Manchester, Munich, Paris and Tokyo. Our main areas of
practice are corporate, IP, technology and outsourcing and regulatory law.
Our international client base choose to work with us because we provide exceptional lawyers with industry expertise, including the
pharmaceutical and medical device industries. Our strong commercial knowledge of their businesses enables us to work with
them to maximise their market opportunities.
12
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59 Tanner Street, London SE1 3PL, United Kingdom
Tel: +44 20 7367 0720 / Fax: +44 20 7407 5255
Email: sales@glgroup.co.uk
www.iclg.co.uk