Social events were not modest in amount

Complaint Brought

This complaint was made against Crawford Healthcare Ltd by ConvaTec Ltd and related to (1) an alleged breach of clause 3.2 of the code which deals with business courtesies; (2) a possible breach of clause 3.5 of the code which covers bringing the industry into disrepute; (3) a possible breach of clause 3.8 of the code which covers conferences, exhibitions and seminars; and (4) a possible breach of clause 3.13 of the code which covers ethical standards – in this case by encouraging healthcare professionals to breach the Standards of Business Conduct Procedure for NHS staff.

The complaint events coincided with the London EWMA Conference (14 May 2015) and became apparent when photographs appeared on Facebook. These showed Crawford Healthcare Ltd personnel in the company of UK healthcare professionals (including tissue viability nurses) at a champagne reception on the London Eye and afterwards at a London jazz restaurant.

The defence provided by Crawford Healthcare Ltd was that the events in question were not organised by themselves, but by Crawford GmbH (another of the Crawford Healthcare Group of companies) over whom they claimed to have no influence.


The complaint panel rejected the defence in Crawford Healthcare Ltd’s response letter that the events were the sole responsibility of Crawford GmbH. The complaint was deemed relevant due to the presence of Crawford Healthcare Ltd staff at the event. Furthermore, it was stated in a letter from Crawford Healthcare Ltd dated 19 June 2015 that ‘all our employees have been made aware of the SDMA Code of Practice’.

The complaint panel found that clause 3.5 (which refers to promotions and competitions) was not breached. The complaint concerns neither a promotion nor a competition and clause 3.5 was thus not considered relevant.

The complaint panel found that clause 3.8 (which refers to conferences, exhibitions and seminars) was not breached. There was no evidence supplied that the complaint event related directly to the EWMA conference, exhibition or related seminars.

The complaint panel found that clause 3.2 (which refers to business courtesies) was breached. The two social events combined were not ‘modest in amount’ and no evidence was provided for them to be related to a legitimate purpose as described in clause 3.2.

The complaint panel was presented with insufficient evidence to conclude that clause 3.13 (which refers to ethical standards) was breached. In particular, no evidence was provided that indicated inducement had taken place. However, it was considered that the attendance of NHS staff may have been in contravention of the Standards of Business Conduct Procedure for NHS staff.

Complaint adjudicated on 26 November 2015

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