Pharmacy Council

Ethics subcommittee

Draft Code of Ethics for the Pharmaceutical Profession

Ethics is the attitudinal aspect in our relationships with others.

Pharmacists and pharmacy technicians in their daily practice relate with:
- Patients to whom they render a service;
- colleagues;
- other health care professionals;
- the administrative and regulatory authorities; and
- have obligation towards the profession; and towards society.

The aim of this code is to guide and direct pharmacists and pharmacy technicians in the
practice of their profession, to observe key responsibilities and fundamental values which
are inherent to the profession.

This revised code takes into consideration:

- The developments of the pharmaceutical profession,
- The shift in the practice of the profession from being focused on medicines to becoming
centred on patients - patients' specific needs and concerns.
- Patients rights and responsibilities
- The Oviedo Convention, Council of Europe
- The Charter of the Fundamental rights of the EU
- The project of the European Commission and CEPLIS to identify the common values of
the regulated professions in Europe.

The guidelines are divided into five sections

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1. Relationship with the patients and society

1.1 Respect human dignity

Pharmacists and pharmacy technicians in the exercise of their profession should carry out
their role with respect and protection for the dignity of human beings, respect for their
physical and mental integrity, and their fundamental rights and with respect for life.

Pharmacists and pharmacy technicians should respect the identity of individual

patients/clients and their personal and cultural differences, and treat them with courtesy and
with due consideration.

1.2 Establish and preserve a fiduciary relationship

Pharmacists and pharmacy technicians should establish and maintain a professional

relationship with their patients/clients, based on mutual trust.

Pharmacists should be loyal to the trust granted to them by patients/clients and build
confidence in their commitment and competence to achieve the desired objective and
maintain their trust.

1.3 Promote the interest and good of the patient

Pharmacists and pharmacy technicians have as their prime objective the good of the
patient/client and not self-interest.

Pharmacists should place concern for well-being of the patient/client at the centre of their
practice and strive with dedication and commitment to meet the medicines or healthcare
needs of the individual patients/clients. With compassion, empathy, prudence and kindness,
pharmacists provide individualised care based on scientific knowledge, after taking into
consideration the patients'/clients' perception and in the respect of societal interest.

Pharmacists should ensure access to services in the event of an industrial dispute, or conflict
with personal conscience.

• In case of an industrial dispute pharmacists and pharmacy technicians should ensure that
their action would have minimal effect on the wellbeing of patients/clients and society.

• Conscientious objection- If the service being requested by the client/patient is in conflict

with the moral integrity of the pharmacist, the client/patient should be informed that the
pharmacist cannot render such service because of his conscience and should be directed
to alternative sources for the service requested.

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1.4 Act with Honesty and Integrity

Pharmacists and pharmacy technicians should act with honesty, integrity and with conviction
of conscience.

Pharmacists should strive to provide truthful, accurate and objective information and advice
in a manner which is easily understood by patients/clients, respecting a relationship of
mutual trust. Pharmacists should, when appropriate, direct the patient/client to appropriate
sources of information.

Pharmacists should respects patients'/clients' wishes not to be informed about their treatment
or condition. However, possible consequences of this refusal should be outlined.

Pharmacists should acknowledge the limitations of their knowledge and skills, and know
when to consult others with more experience and skills, and when to refer.

1.5 Respect patients' autonomy

Pharmacists should encourage and empower patients/clients, or in certain circumstances their

carers/guardians, to actively participate in decisions about their health and to manage their
condition to reach the desired objective. This should be done when appropriate in partnership
with other professionals, and entails mutual respect and an open dialogue.

1.6 Respect and safeguard confidentiality

Pharmacists have an obligation to respect and safeguard confidentiality and should not
disclose voluntarily without the informed consent (preferable written) of the patient/client
information and facts entrusted or made known to them in the exercise of their profession
without due cause.

Pharmacists have an obligation to safeguard confidential information contained in records,

whether kept manually or in a computer system, which includes personal details and
medications. They should ensure that effective mechanisms are in place to protect privacy
and restrict access to these records. Access to these records within the pharmacy is restricted
to those who are themselves subject to an obligation of confidentiality to enable continuity of
care of patients/clients.

1.7 Give the same dedication and care to all

Pharmacists should give the same dedication, care and attention to everyone. In rendering a
pharmaceutical service they must ensure that the individual needs of their clients/patients are
met and that they are treated equally.

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1.8 Serves the needs of society

Pharmacists should be attentive and sensitive to the well-being and healthcare needs of
society they come across in fulfilling their mission. In such situation pharmacists should
recognise their responsibilities and act accordingly

In allocating healthcare resources, pharmacists should ensure that such allocation is fair,
equitable and based on solidarity.

Pharmacists should endeavour to promote measures designed to prevent ill health, and to
promote healthy lifestyles.

2. Responsibilities towards the profession

2.1 Uphold the dignity of the profession

Pharmacists and pharmacy technicians must strive to uphold the dignity and respect of the
profession.

They must maintain high standards of personal and professional conduct in conformance to
their role as health care professionals and abstain from any behaviour or activity likely to
bring the profession in disrepute or undermine public confidence in and respect for the
profession even outside the exercise of the profession.

2.2 Preserve professional independence

Pharmacists must preserve the independence of their professional action by the freedom to
exercise professional judgement.

Professional judgement should be objective, impartial and independent of financial and

commercial pressures, any external, technical, or moral constraints and other conflicts of
interest. Pharmacists should avoid practice environments, or work conditions if their
professional judgement is in any way affected or they are unable to comply with their
responsibilities or impair actions that compromise the best interests of patients

2.3 Personal professional responsibility

Pharmacists in rendering professional services, should exercise personal professional

responsibility on their owe credibility and are morally accountable for their decisions.
Pharmacists are personally accountable for all activities of pharmacy technicians, and other
staff under their supervision.

Pharmacists and pharmacy technicians should ensure that:

• All the laws and subsidiary legislation affecting the pharmaceutical profession,
applicable to their area of practice are invariably observed,

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• They only accept to undertake and perform certain tasks if they have the requisite skills
and knowledge for the tasks to be performed,

• Their practice procedures are accomplished with care and attention and in accordance
to rules of codes of practice and subsidiary legislation applicable to their area of practice,

• If any tasks are to be delegated they are delegated to persons able to perform them,
.
• Before accepting employment they disclose any conscientious objection and other factors
which may affect their ability to render certain services,

• They comply with the Guidelines issued by the Pharmacy Council.

2.4 Maintain and develop competence to practice

Professional competence is inherent to being credible in all relationships with

patients/clients, society and other healthcare professionals.

Pharmacists and pharmacy technicians should maintain and develop professional

competence in their area of practice so as to be able to provide an effective and adequate
service which is of high quality, up to date and evidence based.

2.5 Contribute to the development of the profession

Pharmacists should strive to be innovative in their endeavours to develop the pharmaceutical

services they render to patients and society in line with their needs.

2.6 Educate and train future generation of pharmacists

Pharmacists should assist in the education, training and professional formation of future
generation of pharmacists and pharmacy technicians.

Pharmacists should serve as role models of future pharmacists and pharmacy technicians
and should foresee how their attitudes and dispositions towards patients/clients, colleagues,
and other health care professionals would influence the attitude of future pharmacists and
pharmacy technicians and to present model standards of professional behaviour.

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3. Relationship with colleagues and other health care professionals

3.1 Cooperate with colleagues and other health care professionals

Pharmacists should communicate and collaborate with colleagues and other health care
professionals in enabling patients to achieve their health care needs and to promote the
wellbeing of society.

Pharmacists should establish and maintain good professional relationships with colleagues
practising in other areas of practice and other health care professionals based on mutual trust
and mutual respect and respecting each other’s professional independence and conscience.

In interacting with other health care professionals and with colleagues practising in other
areas of practice, pharmacists should contribute their technical and scientific expertise so as
to facilitate a reciprocal exchange of knowledge and information.

Pharmacists must avoid any action that can jeopardize the relationship of a patient/client
with a colleagues or with another health care professional, or impair confidence in them.

Commercial or financial interests should not motivate or underlay the professional

relationship with other health care professionals and colleagues practising in other areas of
practice to obtain advantages to the detriment of patients or clients

Pharmacists should not recommend a particular health care professional, clinic, laboratory or
hospital unless specifically asked to do so by patient/client.

3.2 Loyal to colleagues

Pharmacists and pharmacy technicians should mutually help and assist one another in the
fulfilment of their professional duties. In all circumstances they must show loyalty and
solidarity towards one another.

In situations where pharmacists have good reason to belief that a colleague may not be fit to
practice the profession they should act immediately to safeguard patients/clients, society and
the profession.

4. Relationship with the regulatory and administrative authorities

4.1 Collaborate with the competent authorities

Pharmacists should assist and collaborate with the competent authorities in a relationship
based on mutual trust to reach their objectives and to safeguard public health

In turn, pharmacists practising their profession in the regulatory and administrative

authorities should show respect to their colleagues and give them the necessary guidance and
support to fulfill their obligations.

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5. Advertising

5.1 Patients and public to freely choose their pharmacist

Pharmacists should not promote or do any activities that limit or prevent in any way
patients/clients to freely choose their pharmacist. They must abstain from all competition
which is disloyal.

Pharmacists should not use their honoury titles and position; and elective, administrative and
academic positions to increase their clientele.

It is contrary to public interest and to the dignity of the profession for pharmacists to secure
clients/patients or promote one's professional advantage by procedures contrary to public
interest and to the dignity of the profession. These include:
• To advertise or promote, whether directly or indirectly;
• To procure, sanction or assent in the publication or broadcasting of notices commending
or directing attention to the professional skill, knowledge, service or qualifications or
depreciating those of others;
• Associate with or be employed by those who sanction such advertising or publication;
• Promote or employ an agent for the purpose of securing clients.
• Or sanction or associate with or be employed by those who sanction such employment

5.2 Personally responsible for publications and educational material under their name

The announcement of lectures to be given by any member of the profession should not in any
way be commendable to him.

It may be permissible for pharmacists and pharmacy technicians to engage in publishing

material suitable for the lay public, either in the form of newspaper articles, mailshots,
pamphlets, books, emails or websites, provided that in so doing every member of the
profession must hold himself responsible for any improper or undue self advertising.
This does not, however, apply to entries in normal type in a street or telephone directories, to
books on scientific or professional subjects or to articles or correspondence in professional
journals. Members of the profession should exercise caution in granting interviews to newspaper
reporters and will assume full responsibility for anything appearing in print as a result thereof.

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Explanatory notes

1. Relationship with the patients and society

1.1 Respect for human dignity

Dignity is defined both as an intrinsic value and as a matter of constructive morality of

human relationships. Human dignity refers to the inviolability and the moral responsibility
of the human person. It expresses the outstanding position of human beings in the universe.
In the context of human rights, human dignity expresses the intrinsic worth and fundamental
equality of all human beings.

Respect for patients/clients as persons, for their identity, and for their physical and mental
integrity is a moral requirement in human relationships. Patients/clients should be accepted
as they are. For this reason, care should be holistic and individualised taking into
consideration patients'/clients' specific physical, and psychological needs, and, recognising
and respecting their unique qualities, feelings, values, beliefs and preferences.

Patients and clients have rights. These are expressed in charters and in the law, and need to
be respected.

1.2 Establish and preserve a fiduciary relationship

Pharmacist-patient or client relationship is fundamental to pharmacy as it is through this

interpersonal relationship that pharmacists and patients/clients derive their rights and
responsibilities. Pharmacists and patients/clients must trust each other when they relate with
each other as it is trust that establishes and safeguards the pharmacist-layperson interaction
and co-operation particularly in the context of the clinical encounter. Human relationships
are based on trust in believing in those who are reliable to tell the truth and trusting those
who are reliable in their relationships to others. Pharmacists are trusted when they respond to
patients'/clients' need for help and assistance, and build confidence in their willingness to use
their competence to promote patients'/clients' well-being.

Trust should be engendered and build up gradually by fidelity to the trust granted by
society. Through the giving of a license by the State, society entrusts pharmacists by giving
them the exclusive rights to practise their profession. Such license permits patients/clients to
place their health in the hands of professionals whose competency they cannot easily judge.
In return for this gift from society, pharmacists gives competence and commitment to
engender and maintain their trust.

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1.3 Promote the interest and good of the patient

Promoting the good of the patient is the goal of pharmacy and is expressed in the mission of
pharmacy to provide medicines, other health care products and services to meet the
individual needs of patients/clients and is based on the principle of beneficence.

Pharmacists and pharmacy technicians must always put the good of the patien/client before
personal, commercial and financial interests. They should not take advantage of the health
status and vulnerability of patients/clients to make undue profit. Patients/clients are referred
in terms of vulnerability because they do not possess the specialised technical knowledge and
because of the effect their illness has on them.

The primary focus of the pharmacist should be the patient. Pharmacists in all areas of
practice must constantly safeguard patients/clients' access to effective and safe medicinal
products which are of good quality and provide pharmaceutical services that meet the
expectations of patients and society. These expectations may include: information about
medicines, being involved in decisions about their health and refusal to dispense or supply a
medicinal product if pharmacists suspect that that it may harm the patient, as it is
inappropriate, or because of a potentially interaction. If the case of such medicinal product is
ordered on prescription, pharmacists should advice the prescriber.

Through beneficence pharmacists promote the well-being of patients/clients. Well-being is

an individual perception based on the notion of what a person considers to be good. The good
of the patient cannot be defined by the pharmacist, what the pharmacist using his
knowledge and experience thinks is best for an individual patient, but must be established in
mutuality through an open dialologue with the patient, after taking into consideration his
experience of illness and his perception of what is good. A decision which the patient
perceives to be good takes into consideration the values, feelings , desires, beliefs and
preferences of that particular, individual person.

To order to promote the well being, it is fundamental for pharmacists to initiate a dialogue
with patients/clients and to ensure that it continues throughout the professional relationship.

Societal interests may impinge on the pharmacist-patient/client relationship, Pharmacists

should recognise the responsibilities of promoting the well-being of a patient on one hand
and on serving the needs of society on the other hand. These needs may include abiding to
protocols regarding the use of specific treatments thereby abiding by national allocation
procedures, allocating resources in an equitable manner and protecting members of society
from harm.

Conscientious objection - Whilst a pharmacist has a responsibility to promote the well-being

of patients/clients he also has responsibilities to preserve his own integrity and to follow his
conscience. However, this does not negate his responsibility to refer the patient/client to
other sources for the service requested. Conversely, a pharmacist should also respect the
patient's values and not to impose his morals. In doing so the moral integrity of both the
patient/client and the pharmacist will be respected..

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1.4 Acts with Honesty and Integrity

Central in professional relationships based on mutual trust is the confidence in and reliance
on pharmacists to be of integrity, honest and truthful and to act with conviction of
conscience. Integrity underscores everything that pharmacists and pharmacy technicians do,
it involves moral wholeness and soundness. Pharmacists are honest with patients/clients
when they give them the service that they need, and safeguard their integrity and well being.

When patients/clients, other health care professionals and pharmacists seek information they
strive to acquire the truth, the truth about medicines, their condition, the provision of
services. Honesty is essential for persons to tell the truth. Truth telling is part of the respect
pharmacists owe to others. This respect includes respect for the patient's/client's right to
receive information and education and respect for his or her autonomy.

The way information is communicated is important and care should be taken on how the
pharmacist presents the facts so as not to exploit the vulnerability, dependence and fear of
clients/patients. Compassion and benevolence are necessary in communicating information to
clients/patients. Information about their medicines enables them to better understand their
treatment, the risks and benefits associated with the treatment, how to cope with side effects,
what to do in case they occur, as well as how to use them.

There are many sources of information available about health, diseases and medicines.
Pharmacists should guide patients/clients who wish or need further information to reliable,
independent sources.

Patients/clients are free to receive information however pharmacist cannot force unwanted
information on a patient as this violates the patients' autonomy.

1.5 Respects patients' autonomy

Autonomy refers to persons' right to self-determination and recognises their self worth in as
far as their actions affect only themselves. Autonomy is the freedom for persons to set goals,
to make decisions based on reason and the ability to act accordingly, and the capacity to act
responsibly.

As a person, each patient/client has the capacity to understand and decide on issues that
concern his well-being. In the case of patients/clients who are not autonomous, their carers
or guardians can act on their behalf.

Open dialogue is a two way ongoing, mutually beneficial communication between the
pharmacist and the patient/client, in which the patient/client contributes his own experience
of illness, his fears, expectations, values and needs, and the pharmacist responds with his
expertise. At the heart of dialogue is an interpersonal relationship of mutual trust and care.

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Dialogue enables patients/clients to eliminate preconceived or subjective views, to
understand alternative treatments (the benefits and side effects, their costs), participate
actively and responsibly in decisions about their health, and encourage them to participate in
planning the treatment and management of their condition to reach the desired objective.
Thus through dialogue patients/clients make informed choices about their health and
treatment and participate actively and responsibly in their care .

1.6 Respect and safeguard confidentiality

This respect for confidentiality arises from the relationship between pharmacists and
patients. Confidentiality engenders trust between pharmacists and patients/clients enabling
patients/clients to confide personal information in the context of acquiring a service that is
adapted to their specific needs. Confidentiality is part of the principle of autonomy. In
respecting patients/clients, one respects their wishes regarding decisions they make and
such decisions should not be divulged to third parties without their knowledge.

Professional secrecy does not allow pharmacists to discuss and identify specific patients with
other health care professionals unless the law demands it or the patient consents to it

The computerisation of patient profiles in pharmacies should entail measures to protect

information and limit access to data.
.
Pharmacists are referred to the contents of Section 257 of the Criminal Code of Malta Cap 9
and to Professional Secrecy Act of Malta Cap 377 which makes it an offence for
pharmacists to divulge information confided to them or made known to them in the exercise
of their profession; and to the Data Protection Act which provides for the privacy of the
individual in terms of personal data.)

Confidentiality is not an absolute principle and at times it can be in conflict with the interest
of society. There are exceptions prescribed by the requirements of the laws whereby
pharmacists are compelled to give specific information to the public authorities.

1.7 Give the same dedication and care to all

Pharmacists should give patients/clients their due as human beings and enable them to have
equitable care. This is within the principle of justice.

Promoting equity of care means that pharmacists have to balance the time they dedicate to
patients depending on their needs, to ensure that their individual needs are meet and to give
them the necessary care and attention.

Health care needs of a patient/client are determined by what ever is essential to achieve,
where possible, restore and to maintain health. A person could thus be harmed if this need is
not fulfilled. Such need could be: information about medicines, access to medicines,
alleviating one's fears and support and solidarity. The virtue of justice has its roots in
compassion and care. Pharmacists must show care and concern to those who are vulnerable,

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to those who have fears and doubts and who have specific needs. Underlying is a
commitment to the good of others.

Pharmacists should not discriminate amongst patients/clients on grounds of age, social

background, nationality, sexual orientation, religious or political beliefs, personal or
cultural values, nature or origin of their health condition or any other factors.

1.8 Serves the needs of society

Pharmacy has various relationships with society. Both the profession and individual
pharmacists have significant roles to play to promote the well being of society at large.

By being sensitive to the needs of society, or of specific members of society, pharmacists

can advocate, lobby or pursue appropriate means so that patients have access to appropriate
services and treatments, patients' rights are respected and legislation safeguarding the health
of patients/clients and society is in place.

Allocation is defined as an act of distribution of resources (medicines or services).

Allocations in the healthcare system are fair insofar as they arrange resources on the basis of
categories of people who have greater need, or of potential benefits to specific sectors of
society; or on what actions are necessary to make people more equal.

Promoting equity means that the entire population should have access to the necessary
medicines and pharmaceutical services with particular regard being given to those categories
who have greater needs - the handicapped; the elderly; and the weaker members of the
community.

Solidarity is defined as standing together to deal with "life misfortunes". It involves

contributing to the needs of people and extending resources to the weaker members of
society.

In the case of the national health system, pharmacists should abide to specific treatment
protocols, thereby abiding to national allocation systems, and to prevent patients/clients from
accessing services to which they are not entitled.

Pharmacists should contribute to promote health and prevent disease through health
education, dissemination of information, and assisting and collaborating with the authorities
and other constituted bodies on such efforts. Pharmacists should also contribute to the fight
against drug abuse, doping in sport and sexually transmittable diseases.

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2. Responsibilities towards the profession

2.1 Uphold the dignity of the profession

Pharmacists and pharmacy technicians should be seen as exemplary and upright citizens not
only during the practice of their profession but also in their daily life. Collectively,
pharmacists form a reputable and dignified profession. Individually, pharmacists should
consider themselves as representatives of this profession and the life that they lead, will
influence society’s perception of the profession.

Pharmacists cannot exercise another activity, which is incompatible with the dignity of the
profession and with the exercise of professional obligations.

Pharmacists should only sign in their professional capacity, and issue certificates, reports
or other documents of a similar nature containing statements which they know to be true,
clear and correct.

2.2 Preserve professional independence

Professional independence refers to the autonomy of pharmacists to use their professional

judgement about how to act in a particular situation, provided they remain within acceptable
professional practice parameters, act with conviction of conscience and in conformance to
ethical principles, and having regard to patients' rights and respect for life.

2.3 Personal professional responsibility

To be responsible is to accept obligations that pharmacists have by virtue of their

commitment. To have responsibilities implies that pharmacists are morally accountable for
their actions. Pharmacists have specific responsibilities in their relationship with patients as
they safeguard patients throughout the chain from when medicines are being manufactured
until they reach the patient. Pharmacists are accountable to patients, to society and to the
profession.

2.4 Maintain and develop competence to practice

Competence in pharmacy incorporates theoretical knowledge and skills and experience in

applying it to individuals.

Maintenance and development of competence involves updating and advancing their

knowledge, identifying those areas that needs to be developed and acquiring new skills
relevant to their area of practice on a regular basis.

This can be achieved by identifying the appropriate learning activities to address their needs
and implementing them. These learning activities include reading of articles and books,
attendance to lectures and seminars/conferences and continuing education programmes.

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2.5 Contribute to the development of the profession

To innovate means to be creative and original in finding ways to further develop the
profession to meet the needs of society. Such ideas and innovations should be shared with
representatives of the profession and if needed with other relevant professionals.

Development of the profession can also be achieved through research and pilot projects.
Research and pilot projects can either be self-initiated or by participation.

2.6 Train future generation of pharmacists

Pharmacists should assist with the training and education of future generation of pharmacists
and pharmacy technicians as preceptors.

Academics and preceptors should treat their students respectfully and to demonstrate to them
that competence and character are inseparable for a professional.

As role models, pharmacists should give importance to character and professional formation
since appropriate and virtuous behaviour, and the principles that guide pharmacists in their
professional practice are best thought by example in the presence of mentors of virtuous
behaviour. It is from these role models that new graduates acquire the character traits and
professional values that are inherent to the profession.

3. Relationship with colleagues and other health care professionals

3.1 Cooperate with colleagues and other health care professionals

Inherent to establishing a good professional relationship with colleagues and other health
care professionals is dialogue and knowledge and understanding of the other professionals'
roles, responsibilities and expertise.

Cooperation and collaboration involves acting together in solidarity on matters relating to

health to meet the needs of patients/clients and society. Cooperation can provide increased
resources, effective utilisation of expertise and knowledge which can benefit patients/clients
and society. Cooperation is also necessary to stimulate new ideas and creativity.

Pharmacists should abstain from criticising unfairly or passing any unfair comments which
can put colleagues and other health care professionals in disrepute

3.2 Loyal to colleagues

Pharmacists and pharmacy technicians must abstain from making unjust actions or
unjustified written complaints to the Pharmacy Council or any other authority with the
intention of harming a colleague.

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Pharmacists must act quickly to protect patients/clients and the public from risk when they
have good reason to belief that a colleagues may not be fit to practice the profession for
reasons of health, behaviour or competence. They are bound to contact them, directly or
indirectly, to rectify their position or behaviour and if this fails must report the matter to the
regulatory authority or appropriate person. The safety of patients/clients and society must be
the prime consideration overriding ver any personal or commercial loyalties.

4. Relationship with the regulatory and administrative authorities

4.1. Collaborate with the competent authorities

Competent authorities are those entities which are either administrative, policy making or
regulatory and whose objectives are to protect and promote public health and society.

In the interest of the public, pharmacists should not compromise the proper functioning of the
institution or authority designed to protect public health.

Pharmacists must give, to inspectors of the competent authority, access to facilities for the
accomplishment of their mission and comply with their requirements and needs.

5. Advertising

5.1 Patients and public to freely choose their pharmacist

Patients/clients should be free to choose their pharmacist. It is difficult for patients/clients to

easily judge the competency of a professional and the quality of service rendered due to lack
of specialised knowledge. Pharmacists should secure patients/clients through the reputation
they build based on the professional services rendered and on the relationship they build with
patients/clients.

5.2 Personally responsible for publications and educational material under their name

Scientific and educational publications should contain information that is true, correct, not
biased or quoted out of context.

Entries in directories should be in conformity to the Guidelines issued by Pharmacy Council.

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