There has been a growing trend that professionals are being recruited and involved in the promotion of multi-level marketing (MLM) products. Healthcare professionals are also becoming more involved in MLM.

While there is no laws or policies that prohibit such activities, it is to be understood that every person, especially professionals, promoting and participating in such activities need to do so with a clear professional discernment and ethics. Many of the MLM are offering dietary supplements, healthcare products, toiletries and cosmetics etc. and a growing number of healthcare workers are participating in such activities.

As a professional body representing pharmacists in Singapore, PSS would like to urge and remind our members to be vigilant and conduct themselves in the highest professional and moral integrity at all times. Being a respected member of the healthcare team, pharmacists must refrain from engaging in conducts or activities which could undermine patients' and public’s trust in the profession, irrespective of where our member works. The Singapore Pharmacy Board’s Code of Ethics must always be the guiding principles of every pharmacist in the absence of any law that defines clearly the rights from the wrongs. Medical and pharmaceutical sciences are complex, and we can always stay in the moral high grounds if we practise legally, professionally, ethically and apply the best of our scientific knowledge and skills to improve the health of our patients and public.

I am attaching below our Past President, Dr. Camilla Wong’s letter issued to our members on the same subject in October 2004.

Dear Member,

Recently there has been a lot of media hype on multi level marketing (MLM) of health supplements by physicians and how this has been viewed as a compromise of the physicians’ professional impartiality to recommend medical-related products.

The public view pharmacists as health care professionals, thus any pharmacist selling health supplements through MLM give these products credibility and instill confidence in the users that the product is safe and efficacious.

From the society perspectives, I would like to urge all pharmacists to remember our fundamental professional responsibility in making recommendations on the use of health care products including MLM health supplements. It should be based on safety, cost-effectiveness and scientific evidence. Specifically, we should use our expert knowledge to evaluate claims made by any health supplement company.

Thank you for your kind attention.

Yours Sincerely,

Camilla Wong

I am also highlighting some salient points about MLM in Singapore which I hope you will find insightful.

Multi-level Marketing (MLM) is a business model adopted to reach consumers through direct sales of products or services. Very often the consumers are themselves recruited to be part of the marketing network. It is both a direct marketing and franchising business network scheme.
Commissions are earned through the sales of products or services by the network of individuals who are recruited to become the promoters. As the commissions earned through the recruitment of any successive individuals snowball, it is very appealing for expansion of the network through rapid and indiscriminate recruitment. As a result, MLM has considerable image problem due to the conduct in recruitment and the past failures of many pyramid and MLM schemes.

In Singapore, MLM activities is synonymous to pyramid selling and are governed by the Multi-level Marketing and Pyramid Selling(Prohibition) Act. The Ministry of Trade and Industry administers the Act. Any products offered will also have to meet all prevailing laws of Singapore. Not all multi-level marketing techniques are undesirable, therefore the government enacted the Multi-Level Marketing and Pyramid Selling (Excluded Schemes and Arrangements) Order to exclude legitimate businesses from the Act, such as insurance companies, master franchises, and direct selling companies which fulfill certain criteria as elaborated below:

• the benefit received by any promoter or participant is as a result of the sale, lease, license or other distribution of a commodity and not as a result of the recruitment of additional participants;
• the promoter of the scheme shall not knowingly make false or misleading representation or omission relating to the scheme or the commodity;
• the promoter shall not make any representation on the benefits other than those allowed;
• there should be a clearly stated policy on refund or buy-back guarantee.

This Exclusion Order was implemented in June 2000 and amended in 2001.The Commercial Affairs Department (CAD) is the enforcement agency for MLM activities.

More information can be obtained from:
http://app.mti.gov.sg/default.asp?id=567 ; http://app.mti.gov.sg/data/pages/81/doc/frm?LEG?MLMOrder?Act.pdf

Ng Cheng Tiang
President, PSS
30th Oct., 2006