Eunomia perspective · 2025-08-11 · Compliance Programmes, Audits & Training
A Definitive Guide to Crafting a high-quality Policy for a Pharmaceutical Company
Published by Eunomia Pharma Services · Updated
How do you write an effective pharmaceutical compliance policy?
Start with structure, not a blank document. Eunomia’s approach runs from an as-is analysis and a gap analysis against EFPIA, EMA, ABPI and EU requirements, through workflow mapping, to tailored drafting with clear purpose and scope, principles, roles, process, monitoring and links to SOPs.
The policy development process
- Analyse current documentation, workflows and governance.
- Benchmark against the applicable codes and regulations.
- Map the policy to real workflows so it can be enforced.
- Draft lean, practical text with owners and review cycles.
The practical steps above are Eunomia’s operational guidance. See the source notes below for the scope of the external references.
What is the difference between a policy, an SOP and a work instruction?
Separate the governing principle from the steps a colleague must follow. Keeping these layers connected makes documents easier to use and maintain. A small organisation may combine layers in one controlled document; the important point is that users can find the rule, owner, process and required record.
| Document | Purpose | Practical example |
|---|---|---|
| Policy | Explain the principle and responsibilities. | The conditions under which an HCP service may be commissioned. |
| SOP | Define the sequence, owners and decision points. | Request, review, contract, delivery verification and payment. |
| Work instruction | Explain a specific operational task. | How to submit the approved request in the company system. |
| Template or record | Capture the evidence that work was performed. | Documented service need, approvals and completion evidence. |
How do you test a new procedure before rollout?
Give a draft to someone who performs the task and ask them to work through a realistic example. Include a missing document, an absent approver and a request that falls outside the normal route. Note every point where the person needs an explanation that is absent from the draft. Resolve conflicting instructions, confirm ownership and update linked forms together. After rollout, use questions and recurring submission errors to decide what needs clarification. A signed acknowledgement shows receipt; it does not by itself demonstrate that the procedure is usable.
Sources and scope
- EFPIA: The EFPIA Code of Practice
The European industry code for promotion and for interactions with HCPs, HCOs and patient organisations, implemented through national codes.
- PMCPA: 2024 ABPI Code of Practice
The UK industry code, in effect from 1 October 2024 and administered by the PMCPA independently of the ABPI.
External sources accessed 29 September 2026. Check the applicable country rules and current source text for a specific engagement.
