GSK voluntary admission: Incruse + Relvar online ads ran with illegible generic names, missing Relvar PI link and (in some cases) no final certification (AUTH/2787/8/15)

📅 2015 | 🖉 Dr Anzal Qurbain
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Key facts

Case numberAUTH/2787/8/15
CompanyGlaxoSmithKline
ProductsIncruse Ellipta (umeclidinium bromide) + Relvar Ellipta (fluticasone furoate/vilanterol trifenatate)
ChannelOnline/digital advertisements (including Pulse; also referenced Nursing Times and other online journals)
Main issuesRelvar PI not available via link; non-proprietary names not readily readable; some ads published before final certification
Volume/timeframeFive items published online; issues from 20 April to 2 July 2015; three of five released before certification
Complaint received07 August 2015 (voluntary admission treated as a complaint)
Case completed30 September 2015
Applicable Code year2015
Breach clauses4.1, 4.3, 9.1, 14.1, 28.1
No breach clauses2, 16.1
SanctionUndertaking received
AppealNo appeal

Download the full case report (PDF)


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

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What happened

  • GlaxoSmithKline (GSK) voluntarily admitted that some UK online advertisements for Incruse Ellipta (umeclidinium bromide) plus Relvar Ellipta (fluticasone furoate/vilanterol trifenatate) did not meet the 2015 ABPI Code requirements.
  • On 2 July 2015, a senior employee saw a Pulse website banner with a blurry/illegible non-proprietary name and a click-through that provided only Incruse prescribing information.
  • Two other advertisements had similar issues; review of the ZINC job bags showed that for some items final certification had not occurred because signatories had not seen the final form.
  • GSK instructed its media agency to remove all Incruse + Relvar online advertisements on 2 July 2015 and initiated an investigation; two further items with similar issues were identified.
  • Root causes described included: a media plan still referring to “Incruse” rather than “Incruse + Relvar”; a broken URL to a dual-PI PDF leading to replacement PI being requested “for Incruse”; and release errors (misread ZINC code / misinterpreted ZINC notification) resulting in publication before certification.
  • Across five items published online, GSK stated that all five had some illegibility and incomplete prescribing information from 20 April to 2 July; and three of five were released before certification.
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Outcome

  • Breach found of: Clause 4.1 (Relvar prescribing information not provided), Clause 4.3 (non-proprietary names not readily readable), Clause 14.1 (published before certification), Clause 28.1 (internet promotion must comply), and Clause 9.1 (high standards not maintained).
  • No breach of: Clause 2 (particular censure) and Clause 16.1 (training/conversance with the Code) — the Panel accepted that mistakes did not necessarily mean personnel were not trained; no evidence was provided to show lack of training.
  • The Panel noted that while Clauses 4.2 and 4.4 were referenced by GSK, it was not possible to breach 4.2 or 4.4 in these circumstances; the failure was treated as a breach of Clause 4.1 and the Panel made no ruling on 4.2 and 4.4.
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