What happened

• AstraZeneca UK Limited made a voluntary admission that a UK-based employee used his/her personal Twitter account to re-tweet nine tweets about Forxiga (dapagliflozin) and one tweet about Lynparza (olaparib).
• The nine Forxiga-related tweets were originally posted by health professionals after presentation of top-line DAPA-HF study results at the European Society of Cardiology (ESC) Congress (31 August – 4 September 2019).
• The DAPA-HF content related to dapagliflozin use in heart failure; the data presented were not within Forxiga’s licensed indications at the time.
• The re-tweets were positive about dapagliflozin results in heart failure in patients with or without diabetes and included clinical-trial slides/details.
• The employee’s Twitter followers included both health professionals and members of the public.
• The re-tweets were deleted in early September 2019 after the employee was asked to remove them.
• A further re-tweet on the same account about Lynparza (“AstraZeneca’s Lynparza gets EU nod as first-line ovarian cancer maintenance treatment”) was identified and deleted later that day (AstraZeneca stated it was alerted to this on 12 September; it was deleted later that day).
• AstraZeneca stated it reminded employees about its social media policy and reinforced that product-related content (including study results) was not allowed on employees’ personal social media channels.
• The employee had been trained on the Global Standard: Social Media Personal Use in January 2018; updated versions (February 2018 and August 2019) had not been “read and signed” by the employee due to an automated update issue, although the employee was alerted to updated guidance via other channels.
• The Panel noted company announcements in August 2019 that appeared to encourage employees to post certain work-related content on personal social media, which the Panel considered could have contributed to confusion about what was permitted.

Outcome

• The Panel ruled that the Forxiga-related re-tweets promoted Forxiga for an unlicensed indication and advertised a prescription only medicine to the public.
• The Panel ruled that the Forxiga-related re-tweets had not been certified prior to use.
• The Panel ruled that the Lynparza re-tweet advertised a prescription only medicine to the public and had not been certified prior to use.
• The Panel considered the Lynparza re-tweet promoted an unlicensed indication (the Panel noted the ovarian cancer indications appeared to be second line, whereas the re-tweet referred to first-line maintenance treatment).
• The Panel ruled that high standards had not been maintained by AstraZeneca.
• Complaint received: 30 September 2019.
• Case completed: 7 February 2020.

Clauses

• Clause 3.2 (promotion of a medicine for an unlicensed indication): breached (Forxiga re-tweets; Lynparza re-tweet).
• Clause 26.1 (advertising prescription only medicines to the public): breached (Forxiga re-tweets; Lynparza re-tweet).
• Clause 14.3 (certification of material): breached (Forxiga re-tweets; Lynparza re-tweet).
• Clause 9.1 (high standards): breached.

Sanctions

No explicit additional sanctions stated beyond the required undertaking/corrective actions described in the report

ABPI signatory lens

Why this matters: Personal social media activity can still be “promotional” in effect. Re-sharing third-party posts can trigger Code obligations (licensing, public advertising restrictions, and certification), especially where content is accessible to the public.

Where teams typically slip up (interpretation):

• Assuming a personal account is outside company responsibility when the content is product-related and the employee is identifiable/connected to the company.
• Treating “scientific advancements” as a safe category without a clear, operational definition that excludes product-related trial results and indications.
• Relying on training completion records rather than ensuring employees understand practical do’s/don’ts for re-tweeting, liking, and sharing third-party content.

The control that would have prevented it: A clear, consistently messaged global personal-social-media standard that explicitly prohibits engaging with product-related content (including re-tweets/shares), reinforced by periodic attestations and targeted reminders around major congresses and data releases.

What I’d check in an audit:

• Whether the personal social media policy explicitly covers re-tweeting/sharing/liking third-party posts and explains why this can be promotion under the Code.
• Evidence that updated standards are effectively pushed to all relevant staff (version control, attestations, exception reporting for non-signature).
• Consistency between formal standards and internal comms/campaigns encouraging social posting (to ensure they do not inadvertently encourage risky behaviour).
• Congress/data-release playbooks: specific guidance issued before/at major meetings (eg, ESC) on what staff can and cannot share.
• Incident response records: speed of takedown, internal escalation, and follow-up communications/training after identification.

What the sanctions tell you (interpretation):

• The case appears to have been handled through corrective actions (deletion and internal reminders) rather than additional published sanctions, suggesting the Panel focused on remediation and system clarity.
• Even without extra sanctions, the combination of unlicensed promotion + public advertising + lack of certification is treated as serious and multi-clause non-compliance.
• The Clause 9.1 finding signals expectations that companies proactively manage the compliance risks created by mixed internal messaging about social media.

3 questions to ask your team this week:

1. If an employee re-shares a third-party congress tweet naming our product, do we treat that as promotional material requiring Code compliance and certification?
2. Are our internal “encouragement” messages about social posting fully aligned with our formal social media standard, with no ambiguous examples?
3. Can we prove all relevant staff received, read, and attested to the latest version of the personal social media standard—and do we have a process to chase exceptions?

Key facts

Download the full case report (PDF)

Reviewed by Dr Anzal Qurbain (FFPM) — ABPI Final Signatory