AUTH/2471/1/12: Anonymous v Sanofi — Restaurant meeting seen as Christmas social event; inadequate controls over third‑party arrangements

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Key facts

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Case number	AUTH/2471/1/12
Parties	Anonymous (non-contactable health professional) v Sanofi
Issue	Arrangements for a meeting (alleged Christmas party) and hospitality/controls
Date of meeting	Mid December 2011
Venue	Local restaurant (no room hire; not a private room)
Attendance	25 delegates plus one Sanofi sales team attendee; mix included consultants, nurses, GPs, registrars, podiatrists, dieticians and diabetes secretaries
Hospitality cost	Total £953.15; set meals £24.95; total per head £32.81 including drinks; included four meals for non-attendees
Sanofi payment	£503.15 (approximately half); credit card receipt not provided
Applicable Code year	2011
Clauses considered	Clauses 2, 9.1, 15.2, 19.1
Final findings	No breach Clause 2; Breach Clauses 15.2 and 19.1
Sanctions	Undertaking received; additional sanctions not stated
Complaint received	3 January 2012
Case completed	14 May 2012

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

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What happened

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An anonymous health professional alleged that in mid-December 2011 Sanofi and Novo Nordisk paid for what was “clearly a Christmas party” for a local diabetes team (clinicians, nurses and administrative staff) at a restaurant.
The meeting was organised between the clinical lead consultant and the representatives; the complainant said the supposed agenda “did not materialise” and there was only a partition rather than a proper separation.
Sanofi said a consultant diabetologist requested support for an educational meeting (“Diabetes Bringing Teams Together”) due to personnel changes and service review; no company presentations or stand took place.
Sanofi had no copy of the invitation and (initially) no written correspondence with the organiser; the decision to sponsor was based on a verbal discussion.
Agenda indicated a 7pm start with two short presentations and Q&A finishing around 7.50pm; one presentation (six slides) largely covered the consultant’s background and reasons for moving to the area.
Venue was a restaurant area separated from the public but not a private room; no room hire was charged.
Hospitality: set meals at £24.95; total evening cost £953.15 including drinks and four meals for non-attendees; total cost per head £32.81. Sanofi paid £503.15 (about half) but did not provide a credit card receipt.
Appeal Board noted Sanofi had not seen the agenda/invitation/slides or checked the venue before agreeing to sponsor; it also noted the representative’s CRM entry was not provided.

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Outcome

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Breach of Clause 19.1 (upheld on appeal).
Breach of Clause 15.2 (not appealed).
No breach of Clause 2 (Panel breach overturned on appeal).
Clause 9.1 was considered by the Panel to be covered by the ruling under Clause 15.2.

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AUTH/2471/1/12: Anonymous v Sanofi — Restaurant meeting seen as Christmas social event; inadequate controls over third‑party arrangements

Key facts

What happened

Outcome

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