Lincoln Medical website: ‘About us’ page held to advertise POMs to the public (AUTH/2924/12/16)

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Key facts

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Case	AUTH/2924/12/16
Complainant	Anonymous, non-contactable pharmacist
Company	Lincoln Medical
Material	Website statements (‘About us’ page; similar wording on ‘Products’ page)
Main issue	Public access to POM names and indications (advertising POMs to the public; lack of clear separation/restriction online)
Medicines mentioned	Anapen (adrenaline/epinephrine auto-injector), Hidrasec (racecadotril), Wakix (pitolisant)
Complaint received	21 December 2016
Case completed	30 January 2017
Applicable Code year	2016
Breach clauses	9.1, 26.1, 28.1
No breach clauses	2
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 pharmacist complained about statements on Lincoln Medical’s website.
The ‘About us’ page (and similar wording on a ‘Products’ page) named prescription only medicines and gave brief indications, including Anapen (adrenaline/epinephrine auto-injector), Hidrasec (racecadotril) and Wakix (pitolisant).
The complainant said there was no warning screen or restriction for health professionals before the product information was shown, and that this encouraged patient enquiries.
Lincoln Medical said it did not intend to promote POMs to the public, accepted the website required review, and immediately took the website down pending recertification via its copy approval system.
Lincoln Medical said it could not replicate the complainant’s search journey and that search results generally directed to the non-promotional ‘Home’ page; it also noted relatively low web traffic (~4,400 hits/year) and that some products were not currently sold/marketed in the UK.

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Breach of Clause 26.1 (advertising prescription only medicines to the public).
Breach of Clause 28.1 (internet material must comply with the Code; public/HP content separation and access expectations).
Breach of Clause 9.1 (high standards not maintained) due to the seriousness of advertising POMs to the public.
No breach of Clause 2 (particular censure not warranted in the circumstances).
No appeal.

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