Galderma tried to lay the blame on a rogue Key Account Manager (KAM), but PMCPA would have none of it. You won’t believe what PMCPA did.
Here’s some of what PMCPA had to say about Galderma’s lame excuse (find the full report here):
“The [PMCPA] Appeal Board queried why the submission that a lone KAM, acting contrary to company policy, was responsible for the issues in this case, had only appeared as a brief statement in the appeal and not in the various responses to the Panel, especially considering the number of times the Panel had had to ask Galderma for information. Notwithstanding the KAM’s apparent disregard for company policies, Galderma was still responsible for his/her actions under the Code. The Appeal Board questioned Galderma’s care and attention taken in its responses to the Panel and its appeal in this case. External confidence in self regulation relied upon a full
and frank disclosure at the outset. This and the circumstances of the meeting implied a fundamental lack of understanding of the requirements of the Code and a lack of control exhibited by Galderma. The Appeal Board queried how seriously Galderma took its corporate responsibilities under the Code.”