Section 3-1 sets the starting point for all representative conduct. The phrase "carry out activities in compliance with the Guidelines" is brief, but its implications run deep. By explicitly stating that representatives must not engage in activities that contradict the principles in Section 1-3, the GL pulls those foundational principles down from the corporate level and makes them binding on each individual in the field.

The core of this provision: "Compliance" is not passive adherence to instructions. It requires representatives to understand the intent of the GL and act on that understanding. "I did not know what Section 1-3 said" is not a defence.

01What "compliance" actually means — knowing, understanding, executing

Representatives are not expected merely to receive the GL as a document. They are expected to study it, internalise it, and apply it as a personal conduct standard. Genuine compliance has three layers. First, knowing what the GL requires. Second, understanding why each provision exists. Third, being able to execute the right behaviour in concrete field situations. Knowledge without execution is not compliance.

So what: A representative cannot satisfy this obligation by simply following company instructions. They must consult the GL themselves, understand it, and let that understanding shape their in-the-moment decisions.

So why: Field interactions constantly produce unexpected questions and situations. Without a personal grasp of the GL's intent, a representative may provide out-of-scope information or give inaccurate answers. Because "I did what I was told" is not an adequate safeguard for patient safety, individual understanding and judgement are indispensable.

02The Section 1-3 principles as personal conduct standards

Section 1-3 establishes the foundational principles of sales information activities: (a) accurate information grounded in scientific and objective evidence; (b) information that contributes to the appropriate use of medicines; (c) consideration of rules on conflicts of interest at healthcare institutions; (d) activities that do not unreasonably impinge on healthcare professionals' time or work. Section 3-1 requires each representative to internalise these principles as their own action standards.

In practice, if a physician asks a representative about an off-label use, principles (a) and (b) mean that proactively supplying information without an established scientific basis constitutes an activity that violates Section 1-3. The GL depends on each representative being able to make that call independently.

So what: The Section 1-3 principles are not aspirational targets for the company. They are the field-level conduct standards that each representative is personally required to meet. Violations may give rise to individual accountability.

So why: Conversations between a representative and a physician or pharmacist happen in real time. The company cannot intervene afterwards. The accuracy and appropriateness of what is said depends entirely on the representative's own judgement in that moment. Making the principles an explicit personal obligation is the mechanism through which dialogue quality is safeguarded.

03The compliance obligation and the limits of indemnification

The assumption that "using company-reviewed materials provides full protection" is incorrect. Even when the review process has been properly followed, a representative who adds unreview supplementary explanations or provides additional data orally may breach the Section 3-1 compliance obligation. Any information provided beyond the scope of the reviewed material rests on the representative's individual judgement; when that judgement conflicts with the GL, the company's review system does not substitute for personal responsibility.

In practice, compliance requires three things: (1) the self-discipline to limit information provision to the content of reviewed materials; (2) the integrity to say "I will check and get back to you" when asked about uncertain matters; and (3) the transparency to report to a supervisor any activity that the representative believes may contradict the GL.

So what: GL compliance is not the same as following orders. Representatives carry an ongoing duty to assess whether their own words and actions are consistent with the GL.

So why: If inaccurate or inappropriate information reaches a patient's treatment, accountability extends to the individual who delivered it, not only to the company. Imposing an explicit individual obligation structurally prevents "I was just following instructions" from becoming a shield, and confirms that each representative is a responsible, reasoning agent—not a passive messenger.