AUTH/2917/12/16: Janssen representative failed to disclose family links in territory (breach Clause 15.2; no breach Clauses 2 and 9.1)

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Key facts

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Case number	AUTH/2917/12/16
Parties	Anonymous, non-contactable complainant v Janssen
Issue	Conduct of representative; undisclosed family links creating actual/perceived conflicts of interest; allegation of appointment based on family influence
Product mentioned	Invokana (canagliflozin) (promoted in the role)
Complaint received	21 December 2016
Case completed	31 January 2017
Applicable Code year	2016
Breach clauses	15.2
No breach clauses	2, 9.1
Sanctions	Undertaking received; additional sanctions not stated
Appeal	No appeal

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

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An anonymous, non-contactable complainant (stated they were a GP) complained about a named Janssen representative.
Allegation: the representative was appointed purely because of family members’ roles in primary care (parent linked to local CCG/diabetes leadership; representative married to a local GP and related to another).
Allegation included that the representative “bragged” a Janssen manager said previous employers were foolish to let the representative go because the parent could influence prescribing of the promoted product.
Janssen said recruitment was objective/rigorous and not based on family connections; the representative disclosed only that a parent was a locum GP, not the wider diabetes network/CCG-related roles or other close family links.
Janssen later became aware (late 2016) of the parent’s additional role (chair of the local diabetes network) and conducted an additional conflicts-of-interest review; it instructed the representative not to call on family members and then terminated the representative’s third-party contract.
The Panel noted external perception matters where representatives have close links with HCPs/decision makers, and queried why Janssen did not know more earlier and why same-surname calls did not trigger questions.

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Breach of Clause 15.2 (representative did not maintain a high standard of ethical conduct by failing to disclose close family links/roles creating actual or perceived conflicts of interest).
No breach of Clause 9.1 (complainant did not prove on the balance of probabilities that the representative was appointed on the basis of family roles; Janssen could not have appointed on that basis if it did not know the roles).
No breach of Clause 2 (no finding that Janssen brought discredit upon or reduced confidence in the industry).
No appeal.

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