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Consumer advertising

This section explains our approach to advertising our prescription medicines in the US and our advertising for our consumer healthcare products in other markets.

Direct-to-consumer advertising
In the US* we advertise our prescription medicines to consumers through TV and print advertisements. This is known as direct-to-consumer (DTC) advertising. DTC advertising is not permitted in most other markets, although New Zealand, Bangladesh and Korea do allow limited DTC advertising.

Promoting the use of prescription drugs directly to consumers can be controversial. Critics believe that it encourages people to request unnecessary treatment, adding to the burden on healthcare systems.

We believe that responsible pharmaceutical advertising is a useful source of health information for patients. It helps to increase awareness of conditions patients might not appreciate or otherwise know about and educates patients about treatment options. Patients must still consult with their physicians about their condition, the appropriateness of a prescription medicine, and obtain his or her consent before receiving such medicines. In countries such as the US where DTC advertising is common industry practice, we need to ensure that our products are also promoted in this way.

In Bangladesh, we run a DTC campaign for our vaccines, which includes a television commercial and newspaper advertisements. This campaign is titled ‘vaccination for all’ and has been run over a period of three years. It won the International Commercial Excellence Exchange Award 2003 (an internal GSK award) and has been approved by the local regulatory authority.

In 2005, the US pharmaceutical industry association, PhRMA, introduced new Guiding Principles on DTC advertising for prescription medicines. These were launched in January 2006.

The principles state that companies should spend an appropriate amount of time educating doctors and healthcare professionals about new drugs before consumer advertising begins. Advertising should be designed to educate consumers about the medicine and the condition for which it is prescribed. DTC advertising for pharmaceuticals must be accurate and supported by evidence. It must also include information on the risks and benefits of treatments and other options such as diet and lifestyle changes. See a copy of the PhRMA Guiding Principles.

GSK was an early supporter of the new principles and we have reviewed and updated our marketing policies to incorporate all of the PhRMA Guiding Principles, as well as additional requirements, and to ensure compliance with them. Some new provisions implemented in our updated DTC policy include:

• Elimination of ‘reminder’ advertisements – short advertisements that mention the pharmaceutical brand name but not the medical condition it is designed to treat
• Submission of new television ads to FDA for review at least 30 days in advance and at the stage of development where audio and visual components are available.
• Providing information on other treatment options (such as diet and lifestyle changes) for the advertised condition, where such treatment options are referenced in the prescribing information for a product.
• Requiring a reference to PhRMA’s Partnership for Prescription Assistance in branded print ads and branded websites – this programme directs patients to members companies’ low income Patient Assistance Programs.

Marketing practices for non-pharmaceutical products
We advertise our over-the-counter medicines, oral healthcare products, and nutritional products to consumers worldwide. Our advertising is governed by national regulations or codes of practice for advertising. Our internal policies and procedures meet or exceed local laws.

Advertising of consumer healthcare medicines and nutritionals is generally subject to less stringent direct-to-consumer advertising requirements than prescription medicines. GSK Consumer Healthcare has global advertising guidelines which require that claims in consumer healthcare medicine advertisements be consistent with product labelling. In markets that allow comparative advertisements, GSK Consumer Healthcare guidelines require that a comparison of a GSK product to a competitor’s be supported by adequate data.

In the UK, there are concerns that advertising for food and drink is contributing to the rise of childhood obesity. The UK Government’s Health Select Committee has made recommendations for tackling obesity, including restrictions on advertising to children and the placement of vending machines in schools.

GSK Consumer Healthcare has guidelines for advertising to children that meet or exceed local laws and codes of practice. The guidelines on advertising to children prohibit drug advertising designed to appeal to, or targeted at, children below the legally mandated minimum age. For example, in the UK we do not buy advertising space in children’s media and we do not supply vending machines to primary schools.

Sports star sponsorship is important to brands such as Lucozade Sport. Our guidelines on sponsorship state that only people who set an appropriate example should be used for sponsorship, and they should have an appeal that is not solely to children below the age of 13.

In the US, advertising of over-the-counter medicines must comply with governmental advertising guidelines. An advertiser must have a reasonable basis for making a claim before publishing it. Comparative advertising of over-the-counter medicines is permitted in the US as long as the claims are truthful and not misleading. Consumer testimonials and celebrity endorsements are permitted as long as the statements made reflect the honest opinion of the speaker, are true and not deceptive.

GSK Consumer Healthcare is a member of the Consumer Healthcare Products Association (CHPA) which has a voluntary Code of Advertising Practices for Nonprescription Medicines. The guidelines advise against practices such as advertising that implies a casual attitude toward using drugs and suggests an over-the-counter drug can prevent or cure a serious disease that must be treated by a licensed practitioner. GSK Consumer Healthcare advertising is reviewed to ensure it meets government and industry standards.

* In a previous version of this report we incorrectly stated that we advertise our prescription medicines to consumers in Japan. Advertising of prescription medicines is illegal in Japan.

We do not advertise prescription medicines to consumers in Japan, however we do run DTC advertisements to raise awareness of disease among patients and the general public without mentioning prescription brands.

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