← Back to Cases
PMCPA Case

Anonymous v Lilly (AUTH/2220/3/09): Promotional content embedded in “independent” diabetes course and excessive 1:1 meetings with consultant

📅 8 March 2026 | 🖉 Dr Anzal Qurbain
📊

Key facts

⌄
Case numberAUTH/2220/3/09
PartiesAnonymous v Lilly
IssueConduct of representative (education course content/positioning; frequency and manner of calls/meetings)
Complaint received25 March 2009
Case completed24 June 2009 (PDF); Completed 25 June 2009 (PMCPA page)
Applicable Code year2008 (Panel noted events occurred under 2006 Code but clauses cited were the same; considered under 2008 Code)
Breach clausesClause 15.2; Clause 15.4
No breach clauses consideredClause 2; Clause 8.2; Clause 15.3; Clause 18.1; Clause 18.4; Clause 19.1
SanctionsUndertaking received; Additional sanctions: Not stated
AppealNo appeal
Products mentionedHumalog (insulin lispro); Humalin (insulin); Byetta (exenatide)
Notable evidence pointsDay 3 included a Lilly employee’s branded promotional slide deck; 17 1:1 meetings with a hospital consultant in 6 months plus 11 Lilly-sponsored meetings; concerns about call record system not capturing whether calls were requested

Download the full case report (PDF)

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

🤖

Got a question about this case?

Ask one of our 13 specialist ABPI advisors — instant answers, 24/7.

Ask AskAnzal AI
📋

What happened

⌄
  • An anonymous, non-contactable complainant (a member of a practice based prescribing commissioning consortia (PBC) in a PCT) alleged inappropriate conduct by an Eli Lilly representative across multiple activities.
  • Lilly sponsored a university-produced Type 2 Diabetes Foundation Course (five education days plus an exam day), covering diagnosis, lifestyle, treatment and complications; Lilly paid room rental and speaker costs.
  • Course materials included references to medicines (including Lilly’s and other companies’), including some slides from third-party sources and some unattributed slides that also referenced Lilly products.
  • On day three, a Lilly employee delivered a 1.5-hour presentation using Lilly-branded slides (“Initiating and Managing Injectable Therapy in [Type 2 Diabetes Mellitus]. An Electronic Pathway”, ref DBT148 June 2008) promoting Humalog, Humalin and Byetta; prescribing information was included.
  • The agenda named the presenter but did not state she was employed by Lilly, making the promotional session appear to be an integral part of the university course.
  • The complainant also alleged a third-party nurse/audit service was used to switch patients to Byetta and that the representative pushed products for “uncontrolled” patients; Lilly described an Enhanced Management of Type 2 Diabetes (EMD) therapy review service delivered by a third party under practice authorisation.
  • Further allegations included pressuring GPs to prescribe insulin, funding a PBC business plan/protocol, excessive meetings/meals, steering referrals, disparagement of local services, and “free meal” hospitality; most were not established due to lack of evidence.
  • Separately, the complainant alleged an “accomplice” hospital diabetes consultant who spoke frequently for Lilly; evidence showed 11 Lilly-sponsored meetings and 17 1:1 meetings with the representative in 6 months, justified by Lilly as needed to arrange meetings and sign anti-corruption/due diligence forms.
⚖️

Outcome

⌄
  • Breach of Clause 15.2: The Panel considered it inappropriate that a Lilly promotional presentation/material appeared to be an integral part of an otherwise well-recognized independent educational course; the representative had not maintained high standards.
  • Breach of Clause 15.4: The Panel ruled that 17 1:1 meetings with a hospital consultant in 6 months were inconsistent with Clause 15.4 and its supplementary information; arrangements were unacceptable.
  • No breach findings were made for other allegations, including Clauses 2, 8.2, 15.3, 18.1, 18.4 and 19.1 (as applicable to the various complaint points).
  • The Panel did not consider the circumstances warranted a breach of Clause 2 in relation to the training course issue.
  • The Panel did not find evidence that meetings amounted to an inducement to prescribe or that honoraria were otherwise unacceptable (no breach of Clauses 18.1 and 19.1 in that context).
🔒

Unlock the full case analysis

Members get the complete breakdown — Clauses, Sanction, Signatory Lens, Audit checklist, and 3 Key Questions.

Best value
£249/year
Annual — save £99
or
£29/mo
Monthly
Join Now — Instant Access
← All Cases Book a Free Compliance Call

📰 Weekly PMCPA Case Breakdown

One real case. One key lesson. Every week — free.

Subscribe Free