United Arab Emirates: Code Of Conduct For UAE Pharmaceutical Professionals

Last Updated: 29 September 2016
Article by Sara Khoja

The UAE health sector is an increasingly important part of the UAE economy and its national wellbeing. Whilst servicing a growing population (both foreign and national) the UAE is also becoming a hub for companies' regional operations as well as a centre for medical tourism.

With the sector being predominantly privatised (underpinned in large part by private medical insurance) a key concern is to regulate the behaviour and service delivery of professionals within the industry. How to balance the business need to operate profitably with the public interest of patient welfare is an issue at the forefront of the Ministry of Health's strategic vision and regulatory rules. This article is one in a series examining how the Ministry of Health seeks to regulate various professionals whose activities fall within its remit.

The UAE Ministry of Health's professional code of conduct for the pharmacy profession (the Code) outlines the standard of behaviour expected of licenced pharmacists, and associated staff, in the UAE.

Although the Code is directed towards managing the conduct of pharmacists in the UAE, it indirectly imposes obligations on employers and operations. In addition, a pharmacist's failure to comply with the standards outlined in the Code may not only directly affect the individual pharmacist but may also have implications for the pharmacist's employer and/or the operation the pharmacist represents.

Code – Key value principles

The Code focuses on three core value principles: competence, respect and integrity. Interestingly, it states that it is not exhaustive and professionals should therefore be alive to their obligations generally.


This principle requires pharmacists to act competently, providing the best level of care possible in a scientific and compassionate way. Under this principle, a competent pharmacist is committed to maintaining his/her competence through lifelong learning and ensuring that he/she receives adequate in-service training for services the relevant pharmacist is required to perform. Pharmacists must be members of a national or internationally recognised pharmaceutical organisation. Pharmacists also have a duty to review, maintain and improve their knowledge and abilities with the advancement of medical technology and availability of new medicines.

In addition, pharmacists are required to take responsibility for the competency of staff that they directly supervise and competent pharmacists must also have knowledge of first aid.


This principle provides that a pharmacist's primary concern must be for his/her patient and other members of the wider community. According to this value principle, pharmacists are required to respect the patient's culture, race, class or gender, the patient's right to receive safe medicine, fellow professionals and the pharmacy profession. For example, pharmacists should not supply medicine if there is doubt as to the quality, safety or effectiveness of a medicine.

Pharmacists are also required to have respect for the environment when disposing of unwanted medicine, chemicals and other materials. Given that failure to dispose of such materials in accordance with the prescribed regulatory standards may result in a penalty being imposed on employers, training on the safe and lawful disposal of potentially harmful substances should be provided to pharmacists (and all employees responsible for the disposal of such substances).


Finally, pharmacists must be honest and fair in all dealings, including not taking advantage of their position for personal gain. While the Labour Law governs the employment relationship onshore in the UAE and in Dubai Healthcare City, the law does not impose fiduciary duties on employees. In order to bring the pharmacy profession in line with internationally recognised health care standards and ethics, the Code incorporates a number of obligations on pharmacists to act in good faith and to avoid conflicts of interest in the performance of his/her profession.

Interestingly, the Code goes further by expressly stating that pharmacists must live according to reasonably expected standards of behaviour both within and outside of their professional practice. Notwithstanding this, employers should take care if electing to implement disciplinary action on the basis of a pharmacist's conduct outside of work as an employer must have a "valid reason" to terminate an unlimited employment contract under the Labour Law, and a "valid reason" is generally accepted as a performance or misconduct-related reason connected with work.

Under the Code, pharmacists must carry out all responsibilities and duties in a fair and honest manner at all times, ensuring transparency in all financial and contractual matters. This includes not allowing personal benefit to interfere with their professional judgment. Employers should incorporate provisions in pharmacists' company employment contracts requiring them to disclose any potential conflicts of interest upon commencement of employment and throughout employment. In addition, employers and operations should have clear policies in place documenting how potential conflicts of interest are to be disclosed and handled within the organisation.

Additionally, pharmacists must uphold the confidentiality of patient medical records; subject to the prescribed exceptions (which includes where the patient's life is at risk, where a court or officer with authority under law demands disclosure, and where the patient or their legal guardian demands disclosure). Pharmacists should be made aware that unlawful disclosure of medical records may constitute a criminal offence under the UAE Penal Code (as it is a criminal offence to infringe an individual's privacy, as well as to publish/disclose personal or sensitive personal data to third parties). Given the importance of maintaining confidentiality of patient records, this should be reflected in the pharmacists' employment contract.

Sale of Drugs

Pharmacists and medical professionals (nurses, doctors and other practitioners) also need to be alive to their duties with regard to the sale and prescription of drugs. A common practice within the industry is for sales staff to be incentivised by the volume of deals closed and there is therefore a personal interest in persuading pharmacists and associated staff to purchase and prescribe particular drugs. Article 17 of the UAE Federal Law No 4 of 1983 concerning the pharmaceutical profession and institutions (as amended) prohibits pharmacists from encouraging patients to buy medicines through secret deals with others. Offering an incentive to a pharmacist or associated staff to prescribe drugs or promote certain drugs is unlikely to be ethical and it should be noted that bribing (which can be widely defined) a public official or individual carrying out a public function can amount to a criminal offence under the UAE Penal Code. For organisations operating internationally such acts could also fall foul of laws with wide scale application, for example the UK Bribery Act.

Practical Tips

Organisations employing or engaging pharmacists and associated staff should ensure that they are doing the following:

  1. Providing a training programme to ensure the pharmacist is up to date with industry knowledge;
  2. Ensure that employment contracts are properly drafted to include fiduciary duties and contractual obligations to comply with the Code;
  3. Ensure that job descriptions and employment contracts adequately define the supervisory role of the pharmacist; and
  4. Ensure that codes of conduct and clinical governance procedures are in place, and regularly reviewed and notified to staff.

Code Of Conduct For UAE Pharmaceutical Professionals

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on Mondaq.com.

Click to Login as an existing user or Register so you can print this article.

Sara Khoja
In association with
Up-coming Events Search
Font Size:
Mondaq on Twitter
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
Email Address
Company Name
Confirm Password
Mondaq Topics -- Select your Interests
 Law Performance
 Law Practice
 Media & IT
 Real Estate
 Wealth Mgt
Asia Pacific
European Union
Latin America
Middle East
United States
Worldwide Updates
Check to state you have read and
agree to our Terms and Conditions

Terms & Conditions and Privacy Statement

Mondaq.com (the Website) is owned and managed by Mondaq Ltd and as a user you are granted a non-exclusive, revocable license to access the Website under its terms and conditions of use. Your use of the Website constitutes your agreement to the following terms and conditions of use. Mondaq Ltd may terminate your use of the Website if you are in breach of these terms and conditions or if Mondaq Ltd decides to terminate your license of use for whatever reason.

Use of www.mondaq.com

You may use the Website but are required to register as a user if you wish to read the full text of the content and articles available (the Content). You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these terms & conditions or with the prior written consent of Mondaq Ltd. You may not use electronic or other means to extract details or information about Mondaq.com’s content, users or contributors in order to offer them any services or products which compete directly or indirectly with Mondaq Ltd’s services and products.


Mondaq Ltd and/or its respective suppliers make no representations about the suitability of the information contained in the documents and related graphics published on this server for any purpose. All such documents and related graphics are provided "as is" without warranty of any kind. Mondaq Ltd and/or its respective suppliers hereby disclaim all warranties and conditions with regard to this information, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall Mondaq Ltd and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use or performance of information available from this server.

The documents and related graphics published on this server could include technical inaccuracies or typographical errors. Changes are periodically added to the information herein. Mondaq Ltd and/or its respective suppliers may make improvements and/or changes in the product(s) and/or the program(s) described herein at any time.


Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:

  • To allow you to personalize the Mondaq websites you are visiting.
  • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our information providers who provide information free for your use.

Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.

If you do not want us to provide your name and email address you may opt out by clicking here .

If you do not wish to receive any future announcements of products and services offered by Mondaq by clicking here .

Information Collection and Use

We require site users to register with Mondaq (and its affiliate sites) to view the free information on the site. We also collect information from our users at several different points on the websites: this is so that we can customise the sites according to individual usage, provide 'session-aware' functionality, and ensure that content is acquired and developed appropriately. This gives us an overall picture of our user profiles, which in turn shows to our Editorial Contributors the type of person they are reaching by posting articles on Mondaq (and its affiliate sites) – meaning more free content for registered users.

We are only able to provide the material on the Mondaq (and its affiliate sites) site free to site visitors because we can pass on information about the pages that users are viewing and the personal information users provide to us (e.g. email addresses) to reputable contributing firms such as law firms who author those pages. We do not sell or rent information to anyone else other than the authors of those pages, who may change from time to time. Should you wish us not to disclose your details to any of these parties, please tick the box above or tick the box marked "Opt out of Registration Information Disclosure" on the Your Profile page. We and our author organisations may only contact you via email or other means if you allow us to do so. Users can opt out of contact when they register on the site, or send an email to unsubscribe@mondaq.com with “no disclosure” in the subject heading

Mondaq News Alerts

In order to receive Mondaq News Alerts, users have to complete a separate registration form. This is a personalised service where users choose regions and topics of interest and we send it only to those users who have requested it. Users can stop receiving these Alerts by going to the Mondaq News Alerts page and deselecting all interest areas. In the same way users can amend their personal preferences to add or remove subject areas.


A cookie is a small text file written to a user’s hard drive that contains an identifying user number. The cookies do not contain any personal information about users. We use the cookie so users do not have to log in every time they use the service and the cookie will automatically expire if you do not visit the Mondaq website (or its affiliate sites) for 12 months. We also use the cookie to personalise a user's experience of the site (for example to show information specific to a user's region). As the Mondaq sites are fully personalised and cookies are essential to its core technology the site will function unpredictably with browsers that do not support cookies - or where cookies are disabled (in these circumstances we advise you to attempt to locate the information you require elsewhere on the web). However if you are concerned about the presence of a Mondaq cookie on your machine you can also choose to expire the cookie immediately (remove it) by selecting the 'Log Off' menu option as the last thing you do when you use the site.

Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies and we are not aware of any at present that do so.

Log Files

We use IP addresses to analyse trends, administer the site, track movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.


This web site contains links to other sites. Please be aware that Mondaq (or its affiliate sites) are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of these third party sites. This privacy statement applies solely to information collected by this Web site.

Surveys & Contests

From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information requested. Information requested may include contact information (such as name and delivery address), and demographic information (such as postcode, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the functionality of the site.


If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Mondaq stores this information and may contact the friend to invite them to register with Mondaq, but they will not be contacted more than once. The friend may contact Mondaq to request the removal of this information from our database.


From time to time Mondaq may send you emails promoting Mondaq services including new services. You may opt out of receiving such emails by clicking below.

*** If you do not wish to receive any future announcements of services offered by Mondaq you may opt out by clicking here .


This website takes every reasonable precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected using firewalls and other security technology. If you have any questions about the security at our website, you can send an email to webmaster@mondaq.com.

Correcting/Updating Personal Information

If a user’s personally identifiable information changes (such as postcode), or if a user no longer desires our service, we will endeavour to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the “Your Profile” page or by sending an email to EditorialAdvisor@mondaq.com.

Notification of Changes

If we decide to change our Terms & Conditions or Privacy Policy, we will post those changes on our site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

How to contact Mondaq

You can contact us with comments or queries at enquiries@mondaq.com.

If for some reason you believe Mondaq Ltd. has not adhered to these principles, please notify us by e-mail at problems@mondaq.com and we will use commercially reasonable efforts to determine and correct the problem promptly.