Image courtesy of flickr user ZaldyImg

Botox: Reading between the lines

Think you know what Botox® is? You haven’t heard it from the comms team – pharmaceutical PR is one of the most tightly controlled sectors of the industry. But there are ways to get a message across…

By Gabrielle Lane

The coverage appeared in January. The cover story of one of the world’s most influential current affairs magazines presented the findings of a scientific investigation by its crack team of writers. The strapline was hyperbolic. It namechecked a medical brand and extolled the virtues of the product synonymous with it to more than three million readers. Yet no-one in the brand’s PR team wanted the credit.

Welcome to pharmaceutical communications – a sector that stonewalls emails, sidesteps voicemails and routinely admits it is “unsure whether it can help” with media enquiries. Bound by national guidelines that prohibit the promotion of prescription medicines, its senior professionals walk a tightrope of education and commercial-awareness obligations, with the compliance team on speed dial. They cannot even freely name their brand to the consumer press.

“The art of pharmaceutical public relations is what you do in the spaces that are available. That’s where countries vary: the national rules vary, as well as the appetite and experience of the local compliance team,” explains Janet Kettels, vice president of communications and PR for Allergan International. “The nuances can be difficult.”

Allergan is the manufacturing behemoth behind well-known medicines such as Botox*, its brand of botulinum toxin. It is testament to the company’s successful communications strategy that Botox alone generated sales of $2.8bn last year. Indeed, ‘Botox’ is the trademark on the box but also the term used colloquially to refer to the entire product category. Competitors include Dysport and Xeomin.

In the UK, the comms rules around prescription medicines are set by the Medicines and Healthcare Products Regulatory Agency and administered by the Prescription Medicines Code of Practice Authority (PMCPA), an independent subsidiary of the Association of the British Pharmaceutical Industry (ABPI).

The ABPI Code of Practice for the Pharmaceutical Industry only allows for PR activity around the licensed medical uses of a drug. For Botox, that includes treatment of hemifacial spasms (involuntary twitching of facial muscles); wrist and hand disability due to strokes; and severe hyperhidrosis (excessive sweating).

At a macro level, the rules seem straightforward: communications must be “factual and non-promotional”, “putting the treatment in the context of the effects of the disease”, and “not encourage the general public to ask their GP to prescribe the product”. That means the PR strategy is one of health education, as well as financial updates for the business press, while ensuring “use of brand names is kept to a minimum”.


Yet the 31 clauses of the 70-page Code of Practice throw up interesting challenges. “Within a disease education programme, we can talk about the disease, what’s happening and the risks, but, when it comes to talking about treatment options, we must be balanced and list all of them… so the doctor and patient can decide what is right for them,” explains Kettels.

This means published information might namecheck a competitor. “Different companies may have a view on whether they list the generic treatment name or the brand name,” she adds.

In the UK, there is an added complication. When a pharmaceutical product is the only one available for a condition, disease education is viewed as promotional: Botox is indicated for use for a particular type of headache but Allergan is restricted from talking about it. The solution? “In the UK, we must go broader and talk about ‘migraines and headaches’ so we can include other kinds of pharmaceutical treatment as well,” says Kettels.

Not that this information can be slapped on a press release. The PMCPA insists releases must be newsworthy and important within the management of medicine. In practice, this means Allergan rarely uses them except for licensing or pricing milestones.


But there are other ways of disseminating a message. Pharmaceutical firms often partner with patient organisations to educate a target audience about a condition. The alliance is permissible as long as the firm is transparent about the financial support provided. It’s also recommended that there are a set of clear goals and a time frame for the collaboration. In 2015, Allergan declared a £65,000 donation to the Migraine Trust to help it raise awareness of the treatments available. “It helps the patient take another step on their treatment journey and speak to their doctor about management options,” says Kettels. “If it increases the number of patients going to doctors to talk about their health, that’s why a pharmaceutical company would be interested.”

To enhance the medical value of their communications, drug companies can also engage healthcare professionals as media commentators, in the same way that experts are used in other sectors. However, statements by paid third parties fall within the Code of Practice and must be neutral. “The brief needs to be really tight. If they have a misfire in their communication and it gets printed, that is our responsibility,” explains Kettels.

But what a doctor says in their own time, including to the press, is up to them. So highlighting someone as an expert commentator on toxins within your own comms could help the media and patients identify supportive voices in future, when seeking a balanced viewpoint.

It is crucial that a journalist knows who to go to for information. Prevented from proactive campaigning around unlicensed uses of a drug (which in the UK include all but 12 cosmetic and therapeutic uses of Botox), the only way that Allergan and the like can give their views is by answering unsolicited questions from the media. When it comes to those responses, they must be neutral, accurate and concise, and flag the unapproved status of the treatment.

Of course, the media can sniff out a story about off-label uses via their own sources. Scientific discourse, conferences and trade media – including journals – often give insights into investigatory uses of a prescription medicine, and they’re all the more clearly signposted because, in the trade space, the manufacturer can talk ‘brand’.


Allergan opts only for limited social media use – it’s a communications channel as far as the various codes are concerned. Tweets from the company’s Twitter account must be pre-approved by the in-house compliance team, which neuters any interactivity. “I struggle with the fact that social media is a two-way dialogue that needs an exchange – within our pharmaceutical practice, we’ll be limited in what we can say about a product,” reveals Kettels.

Inevitably, however, global connectivity means that information often bleeds across channels from territories where pharmaceutical communications are less restricted (typically, the US and Hong Kong). This benefits the constrained comms professional, but it can also fuel the transmission of inaccurate messages. “There’s confusion around our product and trademark,” says Kettels.

“In some people’s minds, ‘Botox’ is a generic product name, but that is not true: it’s the trademark of Allergan’s line of botulinum toxin products. Adverse events and new uses are frequently reported as being about Botox, when they’re not, and I find it difficult to unpick that,” she explains. “It’s hard for us to say ‘Look at the fact sheet, which lays out what a prescription product does’ without it seeming promotional.”

With the PR’s hands tied, inaccurate reports require a call to the lawyers. Allergan has standard wording that it uses to flag trademark infringements by journalists. “When we see clear breaches of the trademark, we do send corrections. They come from our legal team, but they are polite reminders and not heavy-handed legal letters,” she insists. “Pharmaceutical comms should be done completely in collaboration with the compliance team.”

*Botox is a registered trademark of Allergan plc. For more information about the ABPI Code of Practice, visit

Image courtesy of flickr user ZaldyImg

This article was originally published in Influence magazine, Q2 2017.

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