Section 3-2 sets out the concrete conduct standards that representatives must observe during every visit and every information exchange. Building on the requirement to follow reviewed materials, it lists specific forms of deviation that arise frequently in practice: expressions liable to mislead, the misrepresentation of exceptional data as general fact, and the use of undignified imagery or phrasing that risks inducing inappropriate use.
01Following reviewed materials — the foundation of every activity
All sales information activities must follow materials and tools that have passed the Section 2-3 supervisory-department review. "Following" reviewed materials means more than reciting accurate content. It also means not departing from the intent of those materials in terms of scope, emphasis, or the way scientific evidence is presented.
For example, if a reviewed slide states "Efficacy in patient subgroup A: p = 0.03", and the representative adds orally "So this works for any patient", that is not a faithful rendering of the material. The physician receives not the content of the material but the representative's interpretation of it.
So what: Reviewed materials do not simply constitute one available resource. They define the boundary of the information the representative is authorised to communicate. Anything beyond that boundary is effectively unreviewed information provision.
So why: The review system exists to guarantee the quality of everything the company communicates to healthcare professionals. Once a representative steps outside the reviewed scope, the quality assurance breaks down—and the healthcare professional can no longer assume that what they hear carries the same guarantee as the reviewed document.
02Prohibition of activities liable to mislead — including unintentional cases
Representatives must not engage in any activity that is liable to mislead, whether or not that is the intent. The practical demand here is for representatives to continually consider how their statements, documents, and explanations are likely to be received by the healthcare professional.
Common examples of inadvertent misleading include: (1) emphasising efficacy data while omitting the study design limitations or the narrowness of the target population; (2) leaving the distinction between statistical significance and clinical relevance ambiguous; (3) presenting only publications favourable to the company's product during a visit. In each case, the representative may be using accurate numbers while creating a systematically misleading impression.
So what: "I told no lies" is not a sufficient standard. If what the representative says enables a healthcare professional to form an incorrect impression, the provision is breached regardless of intent. The self-check criterion is not the accuracy of the statement but the impression it is liable to create in the recipient.
So why: If a physician makes a prescribing decision based on a misimpression, the patient bears the consequences. By framing the prohibition around the outcome—the misleading impression—rather than the intent, the GL ensures that "I didn't mean to mislead" cannot serve as a defence. From a patient-safety perspective, the gravity of the result is not reduced by an absence of intent.
03Prohibition of presenting exceptional data as general fact
"Exceptional data" in this context refers to, for example: results from an exploratory subgroup analysis that achieved significance only within a defined subset; secondary endpoints showing significance in a trial where the primary endpoint did not; and findings from single-centre or low-volume observational studies. Presenting any of these as a basis for a blanket claim such as "this medicine is effective for condition X" is a generalisation the science does not support.
Even where such data appear in reviewed materials, the representative is obliged to convey the contextual information—that the result is from an exploratory subgroup analysis, that it was not a pre-specified endpoint, and so on—without omission.
So what: Representatives are accountable not just for showing data but for accurately communicating its nature and limitations. A number can be correct and still create a false picture if its context is stripped away.
So why: Physicians sometimes rely on representative-provided information in their prescribing decisions. If exceptional data is received as a general principle, the medicine may be used in situations requiring greater caution. Faithfully conveying the limits of individual evidence items is directly connected to appropriate use.
04Prohibition of undignified expression and expression that risks inducing inappropriate use
Representatives must not use imagery or language that lacks professional dignity, or any expression that risks inducing inappropriate use or misuse of a medicine. "Lacking dignity" covers exaggerated or sensationalist claims, or invidious comparisons with competing products. Expression that "risks inducing inappropriate use" includes anything suggesting use beyond the approved dose, use in patient populations outside the approved indication, or self-directed changes to dosing or treatment regimens.
The instruction to take "scrupulous care" to avoid any such expression signals a proactive duty—not merely to steer clear of the listed examples, but to maintain a high standard of professional expression across all communications.
So what: This obligation rejects the principle that "if it is not explicitly prohibited, it is permitted." As the person delivering information to healthcare professionals, the representative is personally required to maintain high standards of expression—not merely to avoid specific listed prohibitions.
So why: The provision of pharmaceutical information is a specialised form of communication with direct implications for patient safety. Because inappropriate expression can lead to misuse or overuse that harms patients, representatives are required to consider the downstream behavioural consequences of their words. "Impressive" or "engaging" is not a substitute for "accurate and safe."