All the pharma industry associations in the country like IPA, OPPI, IDMA, CIPI, FOPE, SPIC, etc have to constitute a committee 'Ethics Committee for Pharma Marketing Practices (ECPMP)' for handling the complaints regarding the implementation of Uniform Code of Pharmaceuticals Marketing Practices (UCPMP) issued recently by the Department of Pharmaceuticals (DoP).  

The committee will have three members, represented by the Executive Head of the companies or a nominee from the Executive Head, but not below the rank of Director in the Board of Company.

Besides, there should be a review committee for handling the review of the decisions of ECPMP, if any of the parties (complainant or respondent) desire so. This committee will be named as "Apex Ethics Committee for Pharmaceuticals Marketing Practices (AECPMP)" and will consist of five members, represented by the Executive Head of the companies or a nominee from the Executive Head, but not below the rank of Director in the Board of Company. The members of the committee will be nominated by the Head of the Association.

As per the UCPMP, once a complaint is lodged, the process of enquiry shall be completed by the committee even if it is withdrawn. The Head of the association will personally take note of the complaint.  The Head of the association will refer the complaint to the senior most (by designation) member (Chairman) of ECPMP and also indicate the names of other two members of the committee in case of conflict of interest.  The decision will be made by majority.

When the committee (ECPMP) receives information from which it appears that a company may have contravened the Code, the managing director or chief executive or equivalent of the company concerned will be requested to provide a complete response to the matters of complaint.  It is the responsibility of the respondent company to ensure that a full response is submitted.  The company against which the complaint is made should provide supporting
evidence even if it thinks that the Code has not been breached.

Once it is established that a breach of code has been made by a company, the committee can propose to suspend or expel the company from the Association; reprimand the company and publish details of that reprimand; require the company to issue a corrective statement in the media (covering all media) which was used to issue promotional material textual & audio visual; and also ask the company to recover items from the concerned persons, given in violation of the code.

The UCPMP can be voluntarily adopted and complied with by the pharma industry for a period of six months with effect from January 1, 2015 and it would be reviewed by the DoP thereafter on the basis of the inputs received by the department.