AUTH/2816/12/15: Anonymous v Allergan — allegation of large payments to doctors to endorse Botox (No breach) | PMCPA Case

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Key facts

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Case number	AUTH/2816/12/15
Parties	Anonymous v Allergan
Allegation	Large payments to doctors to endorse Botox and other products
Complaint received	16 December 2015
Case completed	21 January 2016
Applicable Code year	2015
Clauses considered	2, 9.1 and 18.1
Panel decision	No breach
Appeal	No appeal
Sanctions	None
Notable case points	Complainant non-contactable and provided no detail; Panel found no evidence to support allegation; company referenced policies/procedures and transfer-of-value disclosure

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

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An anonymous complainant alleged “large payments made by Allergan to top doctors to endorse Botox and other products”.
The complainant was initially contactable but later became non-contactable and provided no specifics (no dates, recipients, or examples).
The PMCPA asked Allergan to respond in relation to Clauses 2, 9.1 and 18.1 of the Code.
Allergan denied the allegation and described its policies and procedures governing HCP engagements, anti-bribery/anti-corruption controls, consultancy contracting, fair market value (FMV) rates, and internal approval processes.
Allergan stated it disclosed transfers of value as required by the Code and provided aggregate consultant payment figures for 2012–2014.

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No breach of the Code was ruled.
The Panel found no evidence to support the allegation, noting the lack of detail and inability to obtain further information from the complainant.
No breach of Clauses 2, 9.1 and 18.1 was ruled.

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