Professional Documents
Culture Documents
BASE FOR
THE REGION
PAGE 12
DOLIPRANE:
A MOROCCAN
EXCEPTION
PAGE 29
SANOFI: ATTACKING
THE CAUSES OF DIABETES
& MENTAL HEALTH
PAGE 30
COVER STORY
UNCLOUDED
AMBITION
Moroccos High Hopes For Its
Pharma Sector
page 18
MOROCCO
JULY 2015
Zenith pharma,
Zenith pharma,
The Dragon of the Moroccan
The Dragon of the Moroccan
Pharmaceutical Market
Pharmaceutical Market
ZenithPharma is an assertive,
ZenithPharma
an assertive,
committed andisinnovative
committedrm
andthat
innovative
Moroccan
has built a
Moroccan rm
that has
built a
reputation
for itself
at home
reputation
for itself
home
through
dynamic
andatremarkable
through Today,
dynamic
and remarkable
growth.
ZenithPharma
is
growth.inToday,
ZenithPharma
is
ranked
Moroccos
top fteen
ranked in Moroccos
top fteen
pharmaceutical
companies,
after
pharmaceutical
companies,
after
just
eight years in
the market.
just eight years in the market.
Key to this success has been the young and ambitious management team that has been keen
to embrace
new management
techniques,
and above
all, hard
work.keen
Key
to this success
has been the
young andinnovative
ambitiousstrategies,
management
team that
has been
to embrace new management techniques, innovative strategies, and above all, hard work.
Through a combination of high quality service and a strategy of decentralization ZenithPharma
has managed
to stand out
fromquality
the crowd
the
company
is based
in the south ofZenithPharma
Morocco and
Through
a combination
of high
service
and
a strategy
of decentralization
therefore
has
benetted
from
better
access
to
its
customers
and
great
logistics
infrastructure.
has managed to stand out from the crowd the company is based in the south of Morocco and
therefore has benetted from better access to its customers and great logistics infrastructure.
The philosophy of ZenithPharma is based on audacious assets and open-mindedness: serving
the others
by providing
them comfort
and wellbeing.
The
philosophy
of ZenithPharma
is based
on audacious assets and open-mindedness: serving
the others by providing them comfort and wellbeing.
ZenithPharma laboratories strives every day to embrace knowledge and expertise to answer
every
need of laboratories
Moroccan healthcare
professionals
and knowledge
patients byand
providing
high
ZenithPharma
strives every
day to embrace
expertise
to quality,
answer
ecient
and
safe
health
products.
every need of Moroccan healthcare professionals and patients by providing high quality,
ecient and safe health products.
w w w. z e n i t h p h a r m a . m a
www.pharmaboardroom.com
A Solid Base
For The Region
Feature 12
CONTENTS
July 2015
Acknowledgements
PREFACE Morocco
Unclouded
Ambition
Cover story 18
Doliprane:
A Moroccan
Exception
Feature 29
26
Copyright: All rights reserved. No part of this publication maybe reproduced in any form or by any means, whether electronic, mechanical or
otherwise including photocopying, recording or any information storage or retrieval system without prior written consent of Focus Reports.
While every attempt is made to ensure the accuracy of the information
contained in this report, neither Focus Reports nor the authors accept
any liabilities forerrors and omissions. Opinions expressed in this
report are not necessarily those of the authors.
www.pharmaboardroom.com
Acknowledgements
PharmaBoardroom would like to thank:
The Moroccan Ministry of Health
Abdelmajid Belaiche, Director General, AMIP
Hubert de Ruty, President, MIS
Mohamed Houbachi, President, AMMG
Abderrahim Derraji, Founder, Pharmacie.ma
and the industry leaders that we have met for taking the time
to share with us their thoughts, their stories and their ambitions.
A warm thank you for the support, assistance and enthusiasm
we have received from the Moroccan pharmaceutical community.
PREFACE
Morocco
Preface
Morocco is too often overlooked as a pharmaceutical nation.
However, thanks to decades of experience, the domestic pharmaceutical industry is strong, with a well-developed base of
local producers that today manufacture products to high
international standards. The quality of local producers in
Morocco today is somewhat unknown to the outside world,
something we hope to address with this report.
Thanks to Moroccos regional competitiveness, many
multinationals have chosen to establish their regional
headquarters in the country, a nod to its political stability, liberal economy and educated workforce. Indeed, in its
2015 Africa Competitiveness Report, the World Economic
Forum identified Morocco as the most competitive country
in North Africa.
One place where the quality of Moroccan pharma is
well known is in sub-Saharan Africa. Indeed, Moroccan
pharma companies have been making inroads as exporters for years now, benefitting from the vision of King
Mohammed VI to open Morocco to the south. As well as
looking to continue this expansion southwards, many
Moroccan companies are now looking at the possibilities beyond Africa to the north, Europe, and to the west,
the US.
Quietly, sedately then, Moroccos pharmaceutical sector is shining. Domestically, with the introduction of
new healthcare coverage through the RAMED program,
increasing numbers of Moroccos populace are getting
access to medicine; aside from this, manufacturers are
improving standards, MNCs are finding new ways to bring
innovation to the country, and trade continues to flourish. Moroccos ambitions in healthcare are clear, and the
skies overhead are unclouded.
ANGOLA
www.pharmaboardroom.com
MOROCCO IN FIGURES
Industrial Overview
20
13
20
12
20
11
20
10
9
0
20
20
07
6
0
20
20
0
20
0
3
20
69.4 33
nd
COMPETITIVENESS
2014 - 2015
MOROCCO EXPORTS
AN INCREASE OF
21.7
OF ITS PRODUCTION
IN TURNOVER 2012-13
SUBINDEXES
7-8
USD
1.51 0.89 4
BILLION TOTAL
Rank
Value
NORTH
AFRICAN
AVERAGE
MOROCCO ALGERIA
TUNISIA
EGYPT
LIBYA
72
79
87
119
126
4.21
4.08
3.96
3.60
3.48
57
65
85
121
111
4.74
4.64
4.38
3.73
3.86
78
125
94
106
137
3.92
3.34
3.74
3.58
3.03
82
133
93
113
143
350
2.91
3.40
3.18
2.49
INDUSTRIAL UNITS
BASIC
REQUIREMENTS
OF DOMESTIC DEMAND
EFFICIENCY
ENHANCERS
20
INNOVATION &
SOPHISTICATION
FACTORS
0
2
0
1
20
20
99
19
20
98
97
19
19
19
96
95
19
94
19
93
19
19
92
91
19
19
90
-7%
3.87
4.27
3.52
3.09
www.pharmaboardroom.com
MOROCCO IN FIGURES
Top Players
TOP 10 LABORATORIES
IN VALUES IN 2013
1
2
SANOFI-AVENTIS
0.89
0.88
0.87
MAPHAR
0.83
BOTTU
0.80
GALENICA
2010
2011
2012
Source: AMIP
2013
2014
UNITS IN 2013
(IN THOUSANDS
OF UNITS)
EVOLUTION
20122013
% IN UNITS
VALUE IN 2013
(IN USD
MILLION)
EVOLUTION
20122013
% IN VALUE
MOROCCO
GENERICS
ORIGINATORS
307,426.6
97,856.9
209,569.7
1.5
4.1
0.4
10
31.8
298,771
598,857
2.6
6.7
0.7
100.0
33.3
66.7
www.pharmaboardroom.com
5
LAPROPHAN
7
GSK
9
NOVARTIS
TOP 10 LABORATORIES
IN UNITS PRODUCED IN 2013
1
2
COOPER MAROC
68.2
897,629
3
COOPER MAROC
PFIZER MAROC
SOTHEMA
100.0
SOTHEMA
GALENICA
PHARMA 5
10
BOTTU
3
MAPHAR
5
LAPROPHAN
7
SANOFI-AVENTIS
9
BAYER MAROC
GSK
MOROCCO IN FIGURES
Top Drugs
Market share
in % of value
18.3%
15.4%
11.9%
11.0%
GENERAL ANTIINFECTIVES
NERVOUS SYSTEM
8.0%
APP CARDIOVASCULAR
7.6%
BREATHING APPARATUS
12.0%
7.1%
MUSCULOSKELETAL SYSTEM
APP GENIT- URIN.HORM.SEX
4.5%
DERMATOLOGY
4.0%
SENSE ORGANS
OTHERS
DOLIPRANE
DOLIPRANE
AUREOMYCINE
AUGMENTIN
MICRODIOL
MINIDRIL
OEDES
MICRODIOL
ASPRO
AMOXIL
COQUELUSDAL
ERECTOR
RINOMICINE
CLAVULIN
ADEPAL
VENTOLINE
PERNABOL
SURGAM
10
AMOXIL
10
ACLAV
10
www.pharmaboardroom.com
PREFACE
Morocco
www.pharmaboardroom.com
11
REGIONAL HQs
Multinationals Speak
A SOLID BASE
FOR THE REGION
Preface: Why choose Morocco over other countries in
the region to base regional HQs? The regional managers
of Roche, Bayer and GSK explain.
RALF HALBACH
GENERAL MANAGER, ROCHE
MOROCCO AND HEAD
OF MANAGEMENT CENTER
NORTHWEST AFRICA
Regarding where the headquarters are located for
this region, there are many factors that drive this decision. It is true that Algeria is the biggest market in the
region, has been growing at record rates and still has a
lot of potential. But when choosing the best location
of the regional hub, you need to take a holistic view.
A number of factors play a critical role, including for
example, the ease of doing business, ability to getting
work permits, overall safety, and access to talent.
Right now, Morocco is the hub for our Roche
Management Center Northwest Africa. I think that
Morocco certainly has the potential to become a regional hub for other companies and sectors as well; however, it needs to take action to change certain aspects.
There are currently negotiations happening with the
European Union regarding trade, which could be very
beneficial for Morocco on many levels. It would be a
great opportunity to get Morocco to the next step in
its development. With the stability that Morocco offers,
and the fact that many companies are already represented here, plus its connection with Europe and Africa,
Morocco is a privileged potential hub. But Morocco
must take a more long-term view and not a short-term,
protectionist view.
12
REGIONAL HQs
Multinationals Speak
Sir Andrew Witty, CEO of GSK visits the companys regional office in Casablanca in 2014.
13
THE DOMESTIC
INDUSTRY:
PAST & FUTURE
ABDELILAH
LAHLOU
General manager
of Iberma
Yet the market has opted for a focus on quality and GMP
compliance. Morocco, for making this effort and also thanks
to the National Drug Order, has been able to compete with
Europe in terms of quality. Imagine the efforts that were provided by the manufacturers to reach these levels!
HCLS: What were the consequences of market
organization?
AL: We find the following characteristics today: an industry
of small batches, heavily dependent on imports of APIs, with
high manufacturing costs and limited economies of scale.
With a situation like this, one might have doubted the future of our pharmaceutical industry, but no such thing happened for the manufacturers, who never lost confidence and
faith in their industry. Consumption is constantly growing,
steadily if not exponentially. Indeed, Morocco remains a
poor country so consumption increases at its own pace. In
the 2000s, Morocco also experienced a renewal, a palpable
socio-economic development; the middle class emerged and
drug consumption was able to increase.
Another factor also predominates: in the last five or six
years the country has entered a new phase; social coverage
was very low but became mandatory (AMO mandatory
health insurance), and although it does not provide 100 percent coverage, I defend it as a smart model, for it is better to
improve coverage incrementally than to attempt full coverage all at once.
Today, this coverage goes up to 40 percent and in addition,
there is a system in place for the weakest households: Ramed,
which covers nearly eight million people, or nearly 25 percent
www.pharmaboardroom.com
why we now have to backtrack so we can reconsider our options (organization in ecosystems for instance). The dynamic is very vibrant: investment goes on, the number of market
entrants has multiplied, and a market composed of multinationals at the beginning now includes generic makers
from all over the world, including Indians, Portuguese, and
Spanish companies. All this heralds a continuous evolution
in the drug sector for the years to come.
Morocco has everything to gain from properly creating industries that sustain countries, such as aerospace, automotive,
agricultural and pharmaceutical industries. This is the future
of Morocco, the added value that will allow its development.
Personally and also as a pharmacist, I am committed to this
end. It is my duty to be a responsible manufacturer! I believe
that everyone has understood these needs and that it is why
this industry even exists, even if it is not a bed of roses.
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15
MANAGING
THE PRICE CUTS
PharmaBoardroom asks MEHDI ZAGHLOUL, country
president and general director of Novartis Morocco, and
former president of Maroc Innovation et Sant(MIS), what
were the main achievements of his term at the association.
The main achievement was to help the industry overcome a very tough period that began with the implementation of a new price law in Morocco. The first step was dealing with the impact that the announcement had on the
market in January 2014. The market shrank by around
4.5 percent, which is significant for an emerging market like
Morocco. Our biggest challenge was to avoid stock-outs and
continue to address distribution issues while restoring confidence across all channels. The second step was maintaining
an open dialogue with the health authorities and ensuring
that the price cut would be linked to a regular reimbursement
situation. For the last three years, all reimbursements were
completely frozen in the country, the official reason being
to re-assess prices in order to manage costs at the insurance
level. One commission per monthis supposed to takeplace,
but for the last four months only one has been organized.
This was painful, butat the end of the day,reduced pricesmeans improvedaccess, which means that ultimately,
the benefitswillbe felt by the wider population.
In 2010, a new methodology for drug pricing was introduced by the Moroccan Ministry of Health based on seven
selected counties (France, Belgium, Spain, Portugal, Greece,
Turkey and Saudi Arabia). The idea was that the set price for
any drug in Morocco would be lower than in those countries.
We persuaded the authorities that while this would be acceptable for newly registered products, for generics it would not.
We finally convinced the authorities to reduce the local price
based on a price average.
16
01
02
Register
as a visitor
using
media code:
CPKR232
03
04
URL:
www.cphi.com/korea/visit/register
Supported by
Organised by
www.cphikorea.com
Join the conversation @cphiww #cphikorea
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17
Morocco
STRAP IN HERE PLEASE
Strap subhead in here please
UNCLOUDED
AMBITION
Photo Credits: Mohamed Melehi | 2015 Courtesy of Loft Art Gallery | www.loftartgallery.net
18
www.pharmaboardroom.com
COVER STORY
Morocco, Unclouded Ambition
www.pharmaboardroom.com
HOUSSAINE EL
LOUARDI
Minister
of Health
MOULAY HAFID
ELALAMY
Minister
of Industry
19
COVER STORY
Morocco, Unclouded Ambition
MOHAMED
HOUBACHI
ABDELILAH
LAHLOU
ABDELMAJID
BELAICHE
President,
AMMG
General manager,
Iberma
Director general,
AMIP
Abdelmajid Belaiche,
director general of AMIP
2012
Price cut on 400
medicines of between
30% and 50%
2014 (JUNE)
Cut on 1,578
medicines of between
30% and 60%
2013
New price cut on
320 medicines of
up to 60%
2015 (JANUARY 1
ST)
Latest cut on 98
medicines
20
COVER STORY
Morocco, Unclouded Ambition
MOHAMED EL
BOUHMADI,
CEO,
ZenithPharma
DRISS CHAOUI
Director general,
Afric-Phar;
HUBERT
DE RUTY
President, MIS
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21
COVER STORY
Morocco, Unclouded Ambition
Courtesy: SANOFI
22
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COVER STORY
Morocco, Unclouded Ambition
KHALID EL
ATTAOUI
BRAHIM
OULAMMOU
AYMAN CHEIKH
LAHLOU
Director general,
Tecnimede
Director general,
Promopharm
Director general,
Cooper Pharma
Another investor, Tecnimede, the Portuguese pharma company, chose Morocco as its first subsidiary outside Europe. Tecnimede was established here in 1999,
explains Khalid El Attaoui, director general of
Tecnimede Morocco. Tecnimede decided in 2009 to
build a new plant in the country. We decided to opt
for Morocco for numerous reasons, El Attaoui remarks. Morocco has for quite a long time had the desire to attract outside investment and as such the necessary fiscal policies have been put in place, policies
concerning the level of VAT and company tax rates.
Also, Morocco, being politically open, has signed a
number of free trade agreements with numerous countries which Europe does not have free trade agreements
with, notably Turkey and the USA.
We have one production plant in Morocco, alongside two partnerships with Polymedic and Sothema,
allowing us to develop local products in the country,
explains Bayers Charpentier. Around 70 percent of
what we sell on the Moroccan market is produced locally. Charpentier goes on to explain that Morocco is also
serving as an export location. This year we are going to
start using our production plant in Morocco to export
a certain number of products, initially to the Maghreb
region and eventually to the wider African continent,
he reveals.
Will companies continue to find Morocco an attractive investment destination, given its relatively
www.pharmaboardroom.com
small market size? In 2011, Jordanian pharma company Hikma acquired Promopharm, a local Moroccan
player. For Hikma, Morocco is very important, first
for its own domestic market but also due to the many
opportunities for entry points it provides into the
region and Africa, explains Brahim Oulammou, director general of Promopharm. While there isnt a pharma
company in Morocco that hasnt found the last few
years difficult, it is important to take a long-term perspective. Hikma remains convinced that Morocco is a
good investment.
23
COVER STORY
Morocco, Unclouded Ambition
COVER STORY
Morocco, Unclouded Ambition
www.pharmaboardroom.com
Europe and North America especially for our patented medicines, explains Ali Bennis, the companys president. To do this, it is building a huge state-of-the-art
new manufacturing plant of 92,000m2 that will conform
to FDA and EMEA standards. We can benefit from the
free trade agreement with the United States to enhance
our exports to this high potential pharmaceutical market,
he explains.
Others believe the industry needs a change of strategy.
We need to find the means to innovate, even if these are
incremental innovations, says Cheikh Lahlou of Cooper
Pharma. Some, such as Abderrahim Derraji, founder of the
website Pharmacie.ma, advocate a more collaborative approach with representatives of the industry speaking with
a unified voice.
What matters is that Morocco is a country where
nothing is impossible, concludes AMMGs Houbachi.
Morocco is a country where we know how to take up challenges the first of them being stability.
25
A CLOSE
PARTNER FOR
MULTINATIONALS
LAMIA BERRADA & SAMIR BACHOUCHI, the chairman
and the general manager of Bottu discuss their flagship
product, Doliprane, the potential for export to the rest of
Africa, and partnerships with European labs.
HCLS: You work with major pharmaceutical companies including Abbott and Boehringer Ingelheim,
to name a few. What is the appeal of Bottu for them?
LB&SB: One of our characteristics is to be among the
laboratories that both work internally developed products
and licensed products as well. We have always been relatively close to multinationals, and we have also developed our
own portfolio of generic products, each business accounting for about half of Bottus overall activity.
Laboratories interested in Morocco meet every potential
partner, and this is where we enjoy a reputation in the market that we are proud of: Bottu is viewed as a professional
team, serious, invested in quality and continuous improvement. We get good press, both with the ministry and professionals of the sector. To be recommended is an honor,
and it helps a lot.
In addition to this, multinationals just dont blindly entrust people with their products, they come to check, send
their own auditors who review the facilities and processes.
Here again, we are proud to successfully complete the different steps, which are challenging every time.
HCLS: Exports are now a highly strategic part of
Bottus development. Can you tell us more about the
African journey of your laboratory?
LB&SB: Exports started with the new management team:
preliminary work began in the mid 2000s, the license was
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27
DOLIPRANE IN MOROCCO
Bottu And Doliprane
DOLIPRANE:
A MOROCCAN
EXCEPTION
Preface: Everywhere in the world, Sanofi controls
the rights to Doliprane. Everywhere except Morocco,
where the drug is the number one product on the
market in both sales and volume.
n 1998, Aventis wanted to retrieve one of its bestknown products from a previous license. After
much negotiation and discussion, we finally agreed
on the purchase of Doliprane and the lines exploitation rights in Morocco, for quite a large amount at
the time, reveal Lamia Berrada and Samir Bachouchi,
chairman and GM of Bottu. This is how since the 2000s,
Doliprane belongs to Sanofi all around the world, except
in Morocco, where it is Bottus property.
Doliprane has been our flagship product, we have
worked a lot on it, there was a particular enthusiasm for
it and thus it has become the identity of our laboratory,
they continue. We also shared a wonderful partnership
with the promotions company we used to work with, and
its leader who was truly passionate about the product.
The work in the field was exceptional, and immediately
propelled Doliprane as a leading product in Morocco,
number one in volume and then in turnover from
the year 2007, exceeding Augmentin.
29
CSR SPOTLIGHT
Sanofi, Diabetes
And Mental Health
SANOFI ATTACKS
THE CAUSES
OF DIABETES
AND MENTAL
DISORDERS
HAISSAM CHRAITEH explains the thinking behind
Sanofis two most recent CSR programs in Morocco,
tackling diabetes and mental health across the more remote
regions of the country.
HAISSAM
CHRAITEH
President and
director general
of Sanofi
Morocco
CSR SPOTLIGHT
Sanofi, Diabetes
And Mental Health
It is important to remember
that this illness does not only
concern educated citizens,
but citizens living in rural areas
with low levels of education
leading to a lack of understanding
concerning the symptoms
of mental illnesses
Aware of the growing challenges posed by these chronic diseases worldwide, Sanofi was the first major health
group to develop a Global Mental Health Action Plan
with a specific focus on access to care for mental health
in developing countries. The Public Private Partnership
for Access to Mental Healthcare was initiated by Sanofi in
www.pharmaboardroom.com
31
RISING STAR
Mohamed El Bouhmadi,
ZenithPharma
THE
DRAGON OF
MOROCCAN
PHARMA
MOHAMED EL BOUHMADI,
the CEO of ZenithPharma, discusses
the potential of Africa for Moroccan
pharma companies, and what it
takes to succeed in the Moroccan
pharma market.
RISING STAR
Mohamed El Bouhmadi,
ZenithPharma
33
FACING
MARKET
CHALLENGES
Morocco has become GSKs
regional hub thanks to the quality
of human capital in the country,
explains the companys area director
RADIA CHMANTI HOUARI,
president and general manager
for North Africa, who also comments
on the reason why she remains
optimistic for the future of Moroccan
pharmaceutical industry.
35
MOROCCAN M&A
Brahim Oulammou, Promopharm
MOROCCO:
THE MISSING
COMPONENT
BRAHIM OULAMMOU, the general director of
Promopharm (a Hikma company) explains why Hikma
decided to invest in the Moroccan market, why a long-term
perspective is needed when judging the governments
reform agenda and how the main priority will always be
responding to patient needs.
HCLS: We have heard that there are many local laboratories specialising in generics and that too much
competition in this area is damaging growth prospects. What is your positioning on the local market?
BO: Our first priority is to respond to local needs. The
Moroccan patient needs to have at his or her disposal
36
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MOROCCAN M&A
Brahim Oulammou, Promopharm
37
ONCOLOGY IN ACTION
Projects To Improve Treatment Levels
FIGHTING
CANCER FROM
THE MAGHREB
Preface: How Princess Lalla Salma, the wife of the King of
Morocco, is helping push the oncology agenda in Morocco.
38
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PharmaBoardroom.com
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39
EXPORT OPPORTUNITIES
Driss Chaoui, Afric-Phar
AFRICAN
HORIZONS
DRISS CHAOUI, general director of Afric-Phar, explains why it is difficult for the
local players to compete with multinationals, how the Moroccan market is being
reformed for the better and why companies should be looking to Africa to boost
their growth prospects.
EXPORT OPPORTUNITIES
Driss Chaoui, Afric-Phar
41
PRODUCTION HUB
Myriam Lahlou Filali,
Pharma 5 Group
SIGHTS
SET ON
THE STATES
MYRIAM LAHLOU FILALI,
CEO of Pharma 5 Group, one of
Moroccos largest pharma companies,
discusses the real potential of Africa
for the countrys drug manufacturers,
the potential for exporting Moroccan
drugs to the US, and the growth
opportunities in the domestic market.
MYRIAM
LAHLOU FILALI
CEO,
Pharma 5 Group
PRODUCTION HUB
Myriam Lahlou Filali,
Pharma 5 Group
43
COMPANY INDEX
Including list of advertisers
Advertisers
COMPANY NAME
Abbott
Afric-Phar
AMIP
AMMG
Bayer
Boehringer Ingelheim
Bottu
Cooper
Genpharma
GSK
Hikma
Iberma
IMS Health
Lalla Salma Association Against Cancer
Laprophan
Ministry of Health
Ministry of Industry
MIS
Novartis
Pfizer
Pharma 5 Group
Pharmacie.ma
Polymdic
Promopharm
Roche
Sanofi
Tecnimede
World Economic Forum
ZenithPharma
44
PAGE #
27
21, 40, 41
5, 8, 9, 20
5, 19, 20, 25
12, 13, 20, 21, 22
27
4, 24, 25, 26, 27, 28, 29
23, 24, 25
23, 25
12, 13, 17, 34, 35
11, 23, 36, 37
14, 15, 19, 20
8, 9, 10
38
25
5, 16, 19
19
5, 16, 21, 35
16, 35, 38
21
24, 42, 43
5, 25
19
11, 23, 36, 37
12, 13, 38
22, 24, 29, 30, 31
22, 23
6
2, 8, 21, 24, 32, 33
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