Biogen Idec strives to provide accurate information, presented in an honest and clear manner, and to price our therapies fairly.
We are committed to providing information that is accurate, supported by scientific evidence and presented honestly and fairly in every context. Our interactions with patients and health care providers are governed by laws and regulations, as well as our Code of Business Conduct and our Comprehensive Compliance Program. All applicable employees undergo regular training and education programs regarding our marketing policies and practices.
In 2010, we revised our Code of Business Conduct to, among other things, update and improve on our policies regarding product information and promotion, as well as our interactions with health care professionals and organizations. All applicable employees were required to take part in online and hands-on training, which used real-world examples to help bring these policies to life.
In 2010, Biogen Idec introduced a new policy for the United States operations on reporting on interactions with customers. This policy formalizes the practice of disclosing payments to health care professionals. It also codifies the expectation that employees and agents are appropriately trained on their roles and responsibilities related to federal and/or state marketing and disclosure laws, including the reporting of data, and that they certify the accuracy and completeness of the data reported by the department or functional area.
We aim to ensure that all of our marketing materials are created and communicated in an ethical and responsible manner. We have a number of product review committees that are responsible for reviewing and approving marketing materials before they are distributed publicly. In 2010, we evaluated our global marketing materials review process to determine how we could improve our practices and enhance consistency throughout our communications. As a result, we adopted a global policy that identifies general principles to be incorporated when global promotional materials are created, as well as a new standard operating procedure (SOP) to be implemented by all affiliates. Each affiliate will receive training on this new SOP beginning in 2011.
Additionally, in 2011, we plan to finalize a new global policy on our interactions with health care providers and patient organizations. This policy will go beyond the ethical principles outlined in our Code of Conduct by specifically highlighting what our employees can and cannot do in various situations. We will also develop an e-learning module, which will be supplemented with local trainings, to help educate and train applicable employees on this policy.
We work to ensure fair pricing of our therapies. Many factors influence the price of our drugs, including the price of competitive products in the marketplace, research and development investments, operation costs and return to our shareholders. We maintain a pricing committee that oversees all aspects of our pricing policies and the sale of our products, including pricing provisions and discounts. The committee is responsible for developing pricing guidelines and meets periodically to assess and update these guidelines, as necessary.
Where allowed by local law, in cases where patients are unable to afford therapies, we help them obtain our products through our ActiveAccessTM program.