Letter of Disclosure Sent to Pharmaceutical Companies

Ann's NOTE: Annie Appleseed Project signed onto this.

Dear [Company],

We are writing to urge you to publish a complete list of all of the charitable and educational grants and gifts made by [Company], its subsidiaries, affiliates and associated foundations. This list should be made available on your company website, include the amounts of each grant and the recipient, and cover grants and gifts made on a global basis. Such a system of disclosure would impose minimal burdens on your company, since it must already compile this information, but the disclosures would have significant public benefits.

There is quite extensive evidence that pharmaceutical industry charitable and educational grants have been abused to influence public health and public policy decisions improperly. For example:

* Purportedly educational programs sponsored by industry may improperly promote drugs for off-label uses.(1)

* Policy think tanks and advocacy groups that receive funding from the pharmaceutical industry often weigh in on important policy debates -- for example, in op-ed pieces -- without disclosing their industry ties.(2)

* Patient organizations receiving industry support often tout products sold by corporate donors, but fail to highlight safety concerns. These groups may also over-promote diseases and drug treatments sold by their corporate donors.(3) They may lobby for inclusion of products on government formularies without disclosing their industry ties, and favor the products of corporate sponsors over others.(4)

* Charitable organizations may be used as a conduit to fund doctors or their research, circumventing normal disclosure requirements and rules.(5)

Disclosing industry funding to charitable and educational organizations is by no means a complete cure for these and related problems -- many of us support much stronger restrictions or outright bans on many industry sponsorship practices -- but it is a start.

The industry has begun to make some modest moves in the direction of disclosure. As you know, one major pharmaceutical company, Eli Lilly, recently began publishing its charitable and educational contributions, at least in the United States. And the Association of the British Pharmaceutical Industry's code of practice requires disclosure of support for patient groups, though not disclosure of the amounts.

It is time now for each company to fully disclose charitable and educational contribution information, on a global basis.

We look forward to your response.

Sincerely,

Essential Action, Washington, DC, USA

Alliance for Human Research Protection New York, USA

Health Action International Africa Nairobi, Kenya

Health Action International Asia Pacific Colombo, Sri Lanka

Health Action International Europe Amsterdam, The Netherlands

Health Action International Latin America Lima, Peru

Initiative for Medicines, Access & Knowledge Delhi, India/New York, USA

Integrity in Science Project, Center for Science in the Public Interest Washington, DC, USA

Knowledge Ecology International Washington, DC, USA

National Women's Health Network, Washington, DC, USA

PharmedOut Washington, DC, USA

Public Citizen, Washington, DC, USA



(1) See, e.g., "Warner-Lambert to Pay $430 Million to Resolve Criminal & Civil Health Care Liability Relating to Off-Label Promotion," U.S. Department of Justice news release, May 13, 2004 ("The company also sponsored purportedly 'independent medical education' events on off-label Neurontin uses with extensive input from Warner-Lambert regarding topics, speakers, content, and participants"). For a fuller discussion of this issue, see "Use of Educational Grants by Pharmaceutical Manufacturers," Committee Staff, Committee on Finance, U.S. Senate, April 2007.

(2) See, for example, Philip Shenon, "On Opinion Page, Lobby's Hand is Often Unseen," New York Times, December 23, 2005.

(3) Tinker Ready, "Divided Loyalties?; Nonprofit Health Advocacy Groups Like to Portray Themselves as Patients' Allies. Can They Serve Corporate Benefactors at the Same Time?." Washington Post, February 7, 2006.

(4) Thomas Ginsberg, "Donations tie drug firms and nonprofits: Many patient groups reveal few, if any, details on relationships with pharmaceutical donors," Philadelphia Inquirer, May 28, 2006.

(5) Reed Abelson, "Charities Tied to Doctors Get Drug Industry Gifts," New York Times, June 28, 2006.

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