Richter’s Compliance Manual includes the Business Conduct and Transparency Policy, which sets rules for liaising with healthcare professionals and patient organisations, as well as for drug law and transparency. The Handbook of Pharmaceutical Legislation, which is part of the Policy, describes in detail, inter alia, the general rules on the content of promotional materials, the mandatory content of information materials if they are intended for professionals, and the requirements for advertising over-the-counter medicines that are communicated to consumers. Richter has identified six principles that should apply to all promotional communications to Healthcare Professionals or Consumers:

• Advertising is not permitted for the marketing of medicinal products for which no marketing authorisation has been granted for the territory in question.
• All information in the promotional material should be in accordance with the information provided inthe summary of product characteristics. Advertising outside the permitted indication is prohibited.
• The information or statements contained in advertising material must not be false or misleadingin any way, in particular through distortion of reality, inappropriate emphasis or omission.
• Promotional materials should be clear, scientifically up-to-date, balanced, and comprehensive enough to allow the reader to form their own opinion. Promotional materials should promote the rational use of the drug by presenting the properties of the drug objectively and without exaggeration.
• All claims made for advertising purposes must be substantiated by substantial evidence; i.e. by reference to an approved summary of product characteristics or other clinically relevant scientific evidence. Claims for advertising purposes should include clear references that also indicate the source of the reference.
• Prior to publication or distribution, all promotional materials must be approved in advance by the Medical Service function or other responsible departments. A precondition for the fulfilment of this principle is that all Affiliates are required to have a medical service function in place that deals with information on the medicines they distribute.

Hungarian medical and pharmacy representatives and regional managers engaged in our marketing activities regularly participate in complex medical and skill development trainings offered by our trainers in accordance with the procedural instructions governing these courses. The parent company also regularly organises professional trainings for product managers working in the domestic and international arena, for example in marketing, medico-marketing, and various management topics.