by Christèle Forget | 6 July 2026

Global HCP Interaction Policy, Adapted for French Compliance Requirements

HCP interaction compliance training · Medical affairs · EN>FR
LanguagesEN>FR
Document typesHCP interaction global training deck · Medical affairs compliance documentation
Regulatory scopeANSM guidelines · EU Directive 2001/83/EC · DMOS / Loi Bertrand (French Sunshine Act – transparency of value transfers to HCPs)
VolumeGlobal training deck · multi-module, covering value transfers, product samples, off-label promotion, and consulting engagements

How a global pharmaceutical company’s HCP interaction training was localized for France, integrating DMOS compliance language that the English source didn’t address.

The client

A global pharmaceutical company operating across European markets. Their HCP interaction training program covers the company’s global policies on interactions with healthcare professionals and organizations, including value transfer rules, product sample management, off-label promotion policies, and consulting engagement criteria. The French-market version is mandatory for field-force and medical affairs teams operating in France.

The challenge

Global pharmaceutical compliance training exists in a structural tension. The English source reflects global policy, and is written to be consistent across all markets. But French law imposes other obligations that go beyond global policy, such as the DMOS framework, France’s Sunshine Act equivalent. It also mandates specific disclosure and transparency rules for any transfer of value to a healthcare professional, with requirements that have no direct equivalent in standard English-language compliance documentation.

A training deck covering value transfers, product samples, and HCP consulting engagements must, in French, use the DMOS-specific terminology that employees will recognize from the French regulatory environment, it can’t just be a translated version of the global policy language. If the French training doesn’t use the same terminology as French healthcare law uses, it fails its compliance purpose, regardless of translation accuracy.

Another challenge is the register of the text. A compliance training deck has to be authoritative enough to serve as the policy reference for the team reading it, but also accessible enough for a commercial or medical affairs professional with no legal training.

An additional constraint: the training was in an interactive e-learning format, with branching scenarios, slide layers, and button states embedded in the source file. The localization had to preserve the functional logic of the interactive elements, like button labels, layer navigation, and decision-point text, as well as the policy content.

The solution

We identified the passages where French regulatory requirements introduced obligations that weren’t covered by the global policy language, and applied DMOS-specific terminology and framing in those sections. This wasn’t just about substituting terminology, it meant the French regulatory context had to be rendered accurately within a document that was originally structured around a different legal framework.

The register was maintained at the level appropriate for internal compliance training throughout: formal, precise, and free of promotional language, consistent with the document’s function as a mandatory reference for field-force and medical affairs teams.

The results

Global compliance training localized for France with DMOS-specific legal framing integrated throughout.
  • DMOS disclosure and transparency terminology applied across the value transfer, product sample, and consulting engagement sections, replacing global policy language in places where French law requires country-specific framing.
  • Policy language rendered at a register suitable for compliance training: authoritative enough to serve as the policy reference, yet accessible enough for field-force and medical affairs audiences without a legal background.
  • Multi-module training deck delivered as a single coherent French document, maintaining structural consistency with the global source throughout.

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