UCB: internal “take-home naloxone” poster deemed briefing material and breached high standards (AUTH/2920/12/16)

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Key facts

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Case number	AUTH/2920/12/16
Company	UCB Pharma Ltd
Complainant	Anonymous, non-contactable ex-representative
Product	Naloxone Minijet Injection (Naloxone Hydrochloride Minijet 400mcg/ml)
Main issue	Alleged off-licence promotion of take-home naloxone; internal poster content and its use as briefing material
Key material	Internal poster (dated March 2012) presented at an internal UCB conference
Complaint received	20 December 2016
Case completed	27 March 2017
Applicable Code year	2016
Breach clauses	9.1, 15.9
No breach clauses	2, 3.2
Sanction	Undertaking received
Appeal	No appeal

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

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An anonymous, non-contactable ex-representative alleged UCB asked reps to promote Naloxone Minijet Injection “take-home” use (community/non-medical setting) for financial gain and target achievement.
The complainant cited differences between UCB’s SPC wording (respiratory depression induced by opioids) and a competitor’s broader wording, plus UK public health guidance encouraging wider take-home naloxone availability.
A poster (dated March 2012) created by a UCB key account manager was presented at an internal UCB conference to share “best practice” and was commended.
UCB argued take-home use was not off-licence per se and that the poster was non-promotional/internal and not a sales briefing.
The Panel considered the poster effectively acted as representative briefing material and assessed its claims.

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No breach of Clause 3.2 (the Panel did not consider take-home use of naloxone Minijet to be off licence per se as alleged).
Breach of Clause 15.9 (poster content advocated claims likely to be in breach; treated as briefing material).
Breach of Clause 9.1 (poor judgement; high standards not maintained in producing the poster).
No breach of Clause 2 (Panel had concerns but did not consider the circumstances met the threshold for particular censure).
No appeal.

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