Competition prizes exceeded the allowed value limit

Complaint Brought

This complaint was made against Crawford Healthcare Ltd by Hartmann UK and alleged that promotional activity contravened sections 3.1, 3.4 and 3.5 of the SDMA Code of Practice.  These sections relate to promotions and competitions.  The promotional activity this complaint relates to was known as the ‘Kaptain Kerrapro Campaign’.  A promotional flyer included the information:

On 17th November 2016, healthcare professionals all over the world will be taking part in the EPUAP Stop Pressure Ulcer Day.  To help you host your own event and raise awareness of pressure ulcers, Crawford Healthcare is providing FREE pressure hero packs full of goodies.


  • Disguise yourself in one of our superhero capes and masks
  • Pressure hero badges to show them who’s boss
  • Prevention posters that pack a punch
  • International Stop Pressure Ulcer Day balloons
  • The chance to share your adventures and WIN prizes

The prizes included iPad Minis, along with other items (‘goodies’).  ‘Superhero’ masks, capes and badges were also involved.


The panel felt that clause 3.1 of the code was not breached because the capes, etc., would not be seen as personal gifts – they would be used in a more general way as part of the awareness-raising International Stop the Pressure Day.  There was also no indication on the capes that they were branded by Crawford Healthcare.  The panel were happy that this activity was part of a general clinical awareness campaign which in no way discredited another company or the industry in general.

Section 3.5 of the code requires that the value of individual competition prizes should have a combined value of not more than £200 plus VAT per event.  However, the panel felt that clause 3.5 was not breached, as additional evidence made it clear that there were two competitions, separated in both time and purpose.  For each competition, evidence was supplied that Crawford Healthcare stayed within the £200 limit per competition, as required by the code.  In addition to the iPads, additional evidence was supplied indicating the other items connected with the competitions (‘goodies’) were in fact ‘give-aways’.  

The panel noted a minor infringement of clause 3.4, where Crawford Healthcare appeared to link their product to a claim.   The cartoon flyer (document provided) stated “and there’s only one way to stop them” immediately followed by “last year Kerrapro Heroes saved the day”.  This could be considered an exaggeration, as it implies only their product could achieve this.  Due to the minor nature of this infringement, the panel recommended that no penalty be applied due to it.

Complaint adjudicated on 8 February 2017

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