Neil Lister has clearly spent some time in the PAGB archives. He’s always been an enthusiast, whether it’s as a passionate advocate for community pharmacy or, as now, talking about the beginnings of an organisation he’s clearly proud to lead at such a special moment. It’s no surprise to discover he’s a history graduate.
“A hundred years is a massive milestone,” he says. “It’s an opportunity to look back at why PAGB was established in the first place, but if I look at our mission statement today, it’s different words, but the sentiment is the same.” He explains further. “It was set up by a group of companies trying to do the right thing in navigating the advertising regulations at the time, to distinguish themselves from others who didn’t do things the right way. That’s still at the heart of PAGB today. That is why it is so enduring.
“What’s more exciting for me than the history is the opportunity to look forward. I think about the conditions that existed in 1919 which led to the creation of PAGB, and I think about some of the conditions now, like the internet, and cross-border medicines regulation. There are foreign competitors, the environment, all sorts of things that are going to create new waves of regulation, the contemporary versions of the catalysts of 1919.” The PAGB board has been working on a new five year strategy. “To do that you need to think five, 10, 15 years out, but for me it’s been an opportunity to think about the next 100 years for PAGB.”
We’re getting ahead of ourselves, though, so we come back to 1919. “There was a report on patent medicines in 1914, but calls for regulation of various industries got knocked on the head during the war,” Neil says. “Suddenly Parliament is able to look at domestic topics again for the first time in five or six years. Fifteen companies come together, saying: ‘stuff is going to happen, let’s figure out what we want to do to create a responsible organisation that’s on the front foot’.”
Links between the consumer medicines industry and pharmacists were there at the beginning. It is known that pharmacist Sir William Glyn-Jones, secretary of the then Pharmaceutical Society of Great Britain and the former MP for Hornsey, was an advocate for the new organisation, and its ambition to represent companies who wanted to do the right thing when presenting their medicines to the public. The lessons for Mr Lister are obvious. “If member organisations are set up with the right values, the right principles, they are going to endure. That is as relevant today in 2019 as it was in 1919.”
That ethos is still at the heart of the self-regulation exercised through the PAGB medicines advertising codes today. The world’s first self-regulating advertising code, in any industry, was created by the PAGB in 1936. “The advertising code was the real breakthrough,” Neil says. “It’s been updated at various times since, but the principles set up were very robust.”
The first PAGB Code contained 10 principles for advertising (see box). “I like ‘No prize competition or schemes should lower the tone of the industry’,” Neil says. “You go to America and you can advertise prescription drugs, you can do celebrity endorsements, but as early as 1936 we said we are not going to do things that lower the tone of the industry. It’s medicines; that’s important stuff there.”
The 10 Principles of the 1936 PAGB Code of Advertising Practice
1 It must be truthful
2 It should not infer the prevention, cure or relief of serious diseases (such as Bright’s disease, cancer, tuberculosis or consumption, diabetes, epilepsy, fits, locomorotataxy, lupus or paralysis) for the cure of amenhorrhoea, hernia, blindness or any structural or organic ailment of the auditory system or for procuring the miscarriage of women or the treatment of habits associated with sexual excess or indulgence or of any ailment associated with those habits. Nor should it diagnose by correspondence or treat any of the above ailments by correspondence
3 It should not suggest to the customer that they are suffering from any serious ailments
4 Testimonial should be honest and limited to the actual view of the user and should be unpaid. No foreign doctor testimonials should imply they are a British doctor
5 No prize competitions or schemes should lower the tone of the Industry
6 Illustrations should be in good taste and should not be distorted or exaggerated
7 It should not imitate trademarks or competitor names or either directly or indirectly disparage or criticise other advertised goods or services
8 No advertising, without authority should infer that the product recommended emanates from any hospital or official source
9 Every member of the Association must take steps to provide his advertising agent with copies of this code
10 Any infringement of the provisions of this code can mean suspension or expulsion.
Today the application of the Codes and the review of member company advertising occupies the majority of the hours worked by PAGB staff every week. The association’s copy clearance team currently approves 10,000 items of copy a year. “With the digital world that could go to 100,000, so we are thinking about how PAGB evolves in the future to make sure we can deliver that member service,” its president says.
“The advertising code was the real breakthrough. It’s been updated at various times since, but the principles set up were very robust.”
It’s a system that works; the number of annual complaints made against PAGB companies about their advertising is in single figures; even fewer are upheld. Mr Lister says the success of the Code over the years has resulted in considerable trust being vested in PAGB by the Government’s medicines regulator, the MHRA. “There are few times I can remember where PAGB has fallen out with the MHRA over something, but it helps that copy clearance is funded by the industry, so that burden doesn’t fall on a Government agency.” He adds that PAGB were founding members of the Code of Advertising Practice Committee of the Advertising Standards Authority; the original CAP drew on the PAGB Code because it was already in existence, so the principles of the PAGB Code were applied across other industries.
If you’re talking about PAGB then you have to talk about self care. “I’m proud of the fact that the PAGB coined the phrase,” Neil says. “I think it was in 1972 when the first NHS Panel on Self Care was sponsored by the PAGB. The NHS has been talking about self care for a long time, and the PAGB has been a catalyst for that agenda for many years. I’m proud and excited about that.”
PAGB’s recent White Paper A long term vision for self care is the latest element in the Association’s support for self care and support for community pharmacy’s role. Noting the contradiction between the NHS Long Term Plan talking about prevention and the role of the pharmacist and the funding cuts, Neil says: “From a pure OTC perspective the opportunity is £1.5bn. What PAGB is pushing for with Government is in line with what pharmacists are asking for. We’re advocating that pharmacists should have a bigger role around patient records, and we think that pharmacists should be able to refer people to other appointments. That will make their role in the high street bigger and more relevant.
“You’ve got the Government with a blunt axe saying we are going to stop reimbursement for OTC medicines – and we supported that, by the way, because we think it’s the right thing – but what there hasn’t been yet is the drive to pull that demand through pharmacies, to let patients know that other options are available to them.
“It’s a time of crisis now. Sorry, but you can’t deliver community pharmacy if there is no pharmacy in the community. It’s the time for unity and to get behind some causes.”
“I’m an optimist. The fact that PAGB has identified some real savings is an opportunity. Taking services lock, stock and barrel out of GP surgeries and putting them into pharmacies, could single-handedly rescue the NHS. And let’s face it, it needs it.” For an unashamed champion of community pharmacy, Neil Lister admits to being frustrated by the sometimes fragmented nature of the sector. “I hope we can help, through my role in Perrigo or PAGB, to create a unified voice that just goes for it and delivers something over time. Even now we are all united on what we disagree with. It’s a time of crisis now. Sorry, but you can’t deliver community pharmacy if there is no pharmacy in the community. It’s the time for unity and to get behind some causes.”
The centenary finds PAGB’s member companies co-operating on the big issues, according to its president. The board is comprised of big and small businesses; everybody on the board has one vote. “I think it works well, because it is in the interest of the big companies that the smaller companies, who can be very disruptive, follow the same codes, regulations and rules. In return, he says, small companies with fewer resources get to share the experiences of their bigger counterparts. He pays tribute to the work Reckitt Benckiser and GSK have contributed to PAGB members over Brexit.
He says work on the new five-year strategy has involved some long days. “It’s important. You are laying down what the next five to 10 years is going to be like for our industry. If we think about the digital world, there will need to be regulation in the industry. If you go back to the founding principles, about being on the right side of the dial, we will want the members to do the right thing. But that challenge is that for the first time it is not up to national governments to regulate around that; you’ve got cross border stuff coming in; companies can be operating in other countries. The need for leadership by PAGB is going to be greater in the next five years than it has been in the previous 30 or 40 with some of what’s coming down the line.”
Since we’re looking forward I ask with the Government signalling the withdrawal of the NHS from the self-treatable conditions arena, whether more POM to P switches might come down the line. Neil notes “good recent progress” but he’s not sure if there’s more to come. He throws the challenge back. “As an industry it’s our job to champion those things when they happen, but this is the point of differentiation for the pharmacist, they have the P medicines, they have the switch, they need to champion those. I see some pharmacists doing that really well. As an industry we need pharmacy to get behind these products; if they work commercially we will be incentivised to try more. If they don’t work, we aren’t going to have an industry driving more things through.”
Neil’s presidency has, of course, been occupied by preparations for Brexit. “Weeks and months,” he says. He switches into Perrigo mode to explain what’s been involved at company level. “We’ve had to transfer all of our licences to other member countries for our exports – smaller companies might not be able to do that. We have had to get quality control labs set up across Europe, because we can no longer assume as a third country that UK testing will be acceptable in the EU. We’ve had to employ people on the continent, sometimes at the expense of UK jobs. I just think about the wasted opportunity of the last three years when we could have been putting our energies into positive things rather than things that may or may not happen.”
He says 95 per cent of member companies are ready, even for ‘no deal’. “I’ve been most proud of the way PAGB has shown leadership, and the altruistic and selfless way the big companies have shared information has been a common good. The frustrating thing, of course, is that this has all been done for something that may or may not happen.” PAGB lobbied successfully for the contingency arrangements that were initially supposed to apply to POM medicines to apply to P and then to GSLs.
Being PAGB president in its centenary year may be a singular honour, but he’s got an important day job too. I remind him the last time I saw him he’d just flown in from the other side of the world. Perrigo’s vice-president international says: “In theory, I look after Russia, South Africa, Australia, New Zealand and bits of America.” He’s also the managing director for the business in the UK and Ireland.
“I’m very grown up these days,” he says, “but I’ve got imposter syndrome as well; I still think I’m 12 and somebody is going to call me out one day and say ‘what are you doing running a big company’? But it’s all about having a good team. My job is no more difficult than anyone else’s, but it’s about having the right structure and the right team. I’ve got a great group of leaders under me. Your job is mostly trying to help get the best out of them, giving them the confidence to do the things they think are right.”
He says Perrigo is becoming a lot more focused. “For many years Perrigo bought anything that was for sale. An Rx company, a patented royalties company, store brands, branded medicines. Our new CEO Murray Kessler, who started in October, is doing a lot to focus the company. That focus now, ironically, is self care. Our redefinition of the company is very much in harmony with what PAGB is doing around self care, because it’s the rising global trend. We define ourselves as a company that wants to make lives better, by bringing quality affordable self care products to consumers everywhere in the world.”
Perrigo is selling off its US prescription medicines division to focus as a “consumer self care (not healthcare) business” not only on its store brand and branded OTC, but on associated products like incontinence, dental care, medicated skin care. Neil says: “We want to be the biggest and fastest growing consumer self care company in the world. It’s exciting.”
“We’re the biggest producer of OTC products globally,” Neil says. “Around 80 per cent of all store brand OTC in the US is made by Perrigo; 350 million people and the biggest healthcare system in the world.” Perrigo’s website says is makes 47 billion tablets every year. “It’s a global strategy, but the UK is probably further along that path than other countries. In Europe, where the tradition is independent pharmacies, it’s not possible to have store brands. In the US, 90 per cent of our products are store brand. In the UK, we’re a top five branded supplier of OTC medicines, and the number one store brand supplier.”
The company is not planning to stand still. “In Ireland we’ve launched the Perrigo brand as a proposition for independent and chain pharmacies. It sits across many different OTC areas, delivering great profit margins for pharmacists, a value brand for consumers, and the highest efficacy and claims for the products. Competing with the multiples is an interesting area for community pharmacies there. In the UK we have the Galpharm brand, but that’s more discounters and convenience than pure pharmacy.” It sounds like watch this space.
Neil is clearly keen to replicate the success he had with Omega Pharma, bought by Perrigo in 2015 in supporting community pharmacy but he realises there’s a way to go yet. “What I really want to happen is that pharmacists and healthcare providers see Perrigo as the company they want to partner with. I hope from that we’ll be rewarded by selling more boxes and growing our business.” The company’s investment in its Warman-Freed Learning Pharmacy in Golders Green is part of that partnership approach. I suggest it might also give the company a unique insight into the current state of community pharmacy. He laughs. “Well, we set it up as a not for profit, and it seems that’s very easy to do in pharmacy. What we try to be is authentic so we can say to independent pharmacy: ‘these are ways you can do things with the resources you’ve got’.”
“Warman-Freed is really important, and I think we could do loads more with that,” he says. “We do the P3pharmacy articles helping pharmacists with practical things that matter to them, but I think around self care where it’s Perrigo’s mission, it’s PAGB’s mission, we want to have a panel that starts laying down the agenda items for what we are going to do next with self care that Warman-Freed tests.”
Timeline: 100 years of the PAGB
1919 First meeting of the Association of Manufacturers of British Proprietaries (AMBP) on 17 June
1926 AMBP rebranded to PAGB (Proprietary Association of Great Britain)
1927 Became a member of the Advertising Association
1936 PAGB published the world’s first self-regulatory advertising code
1939 PAGB asked by Government to set up the Proprietary Medicines Export Group
1959 PAGB authors WHO paper on self-regulation in medicine advertising
1962 Became sponsoring body of the newly created Advertising Standards Authority
1972 Inaugural meeting of the Panel on Self Care
1979 Self-medication book published by Dr John Anderson, the proceedings of the 1978 self care symposium
1989 First joint PAGB/Department of Health Self Care Symposium
1990 First food supplements advertising guideline published
1993 First PAGB OTC Directory published
1998 First PAGB Self Care Conference marking the 50th anniversary of the NHS
2004 Self Care Continuum presented for first time (at AESGP conference)
2006 BROMI (Better Regulation of OTC Medicines Initiative) report published
2011 Self Care Forum established
2016 First PAGB Medical Devices advertising guideline introduced
2019 First PAGB Medical Devices advertising code published in January
2019 Centenary of PAGB, the consumer healthcare association