AUTH/2718/5/14: Anonymous v Allergan (2014) — Meeting arrangements (No breach) | PMCPA Case

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Key facts

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Case number	AUTH/2718/5/14
Parties	Anonymous complainant v Allergan
Issue area	Meeting arrangements; alleged circumvention of approval requirements; alleged delegate selection and slide approval issues
Complaint received	29 May 2014
Case completed	26 June 2014
Applicable Code year	2014
Meeting timing (as alleged / as identified)	October 2013 (alleged) / May 2013 (identified by Allergan)
Meeting description	One-day training course covering pharmacology of botulinum toxins, anatomy around the eyes, eyelid/orbit conditions, and botulinum toxin use around the eye
Venue	Postgraduate education centre at a named hospital (healthcare premises)
Allergan involvement (per company)	Co-sponsorship/stand fee only; planned stand but none placed; no employees attended; no speakers; no content control; no travel/registration/subsistence funded
Sponsorship amount	£1,200
Clauses considered	2, 9.1, 14.1, 15.2 and 19.1
Outcome	No breach
Appeal	No appeal

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

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An anonymous, non-contactable complainant alleged Allergan inappropriately approved materials and selected delegates for a neuroscience/ophthalmology-related training meeting.
It was alleged the meeting was reclassified as a “stand meeting” to circumvent approval requirements, despite being an Allergan-engineered training course.
The complainant alleged the meeting was advertised as a funded training course, that no other companies were present or invited, and that Allergan may have paid delegates’ travel costs.
The complainant alleged slides were approved on the basis that exhibiting costs were shared with other companies, but that slides not processed through Allergan’s Zinc system were used.
Three senior employees were named as allegedly complicit.
Allergan could not identify a meeting in October 2013 as alleged, but identified a relevant event in May 2013 at the same hospital/with the same consultant.
Allergan stated it co-sponsored a third-party organised course (sponsorship fee £1,200), did not select/invite attendees, did not pay travel or registration, did not provide subsistence, and did not provide speakers or influence content; it planned a stand but none was placed and no Allergan employees attended.
Allergan stated it did not receive slides/materials and, as a third-party stand sponsorship with no involvement in content, there was no requirement to certify slides.

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No breach of the Code was ruled.
The Panel considered there were substantial differences between the parties’ accounts and the complainant provided no evidence to support the allegations.
The Panel considered there were grounds to doubt the veracity of the complaint and noted the burden of proof lay with the complainant on the balance of probabilities.
The Panel considered the one-day educational course content and venue were appropriate for sponsorship and Allergan’s involvement (stand fee only) was not unacceptable.

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