The ABPI code ‘did not apply here’

I have submitted the following response to this recent BMJ article: Government consults on legislation to disclose industry payments to doctors:

Dear Editor,

In 2018 Dr Margaret McCartney set this challenge: “Here’s a game: try and find a doctor’s conflicts of interest. Set a timer, and give yourself the freedom of the internet”[1].

I have since retired from medicine. However, back in 2018 I had some experience of playing this “game”. It was a “game” that, on behalf of the public, I lost. I was “playing” against financial backers and paid opinion leaders. The rules of the game were not clear and much seemed to be hidden.

Leaving the metaphor behind, I found that a “consensus” of opinion leaders, in a published article in a leading Journal, was instructing a most significant change of disease definition and for this to be “operationalised” in the NHS. In the declarations of competing interests I noted significant discrepancies and apparent omissions. I noticed this because some of those involved had failed to be transparent in the past. They had also been made aware of this at the time.

Back to the “game”. This is a brief description of a protracted experience. I wrote to the Journal in question. The Journal told me to write to the key author. After several months of correspondence with the key author I was finally sent the ICMJE declarations (International Committee of Medical Journal Editors) of all authors, none of which were in the public domain. These ICMJE declarations confirmed that several of the authors had not submitted declarations before the article was published and that for several of the rest of the authors the ICJME declarations included competing financial interests not included in the publication. Concerned about this, I approached the Association of the British Pharmaceutical Industry (ABPI). The voluntary register they have – Disclosure UK – did not help as most of the authors were not on it. The ABPI therefore advised me to go to the Prescription Medicines Code of Practice Authority (PMCPA). However the PMCPA told me that the ABPI code “did not apply here” [2].

I sought the advice of the General Medical Council (GMC). However the GMC seemed only interested in Fitness to Practice procedures, whereas I was simply wishing all players to follow the guidance (the ‘rules’) as set out in Good Medical Practice. After some further correspondence, the GMC advised me to go back to the Journal where the “consensus” was published. Returned to the start and still no clearer in relation to competing financial interests, I gave up.

It is always possible to cheat in games. In this “game”, the rules were far from clear and there was no referee. In the five years that have since passed such lack of transparency of influential experts continues [3]. Declarations are generally incomplete, inconsistent and subject to insufficient scrutiny. It is time for the UK to introduce Sunshine legislation to enact an independent, central, single, searchable register of competing financial interests in healthcare, science and academia. Without this scientific integrity cannot be assured.


[1] Margaret McCartney: Hiding and seeking doctors’ conflicts of interest, BMJ 2018;360:k13522,  January 2018 .

[2] Aggarwal, A. Executive Director of the ABPI, Rapid response to Unethical pharmaceutical marketing: a common problem requiring collective responsibility. 26 September 2023.

[3] Wise, J. GSK will resume paying doctors to promote its drugs after policy U turn, BMJ 2018;363:k4157, 3 October 2018

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