Novo Nordisk breached ABPI Code over misleading Tresiba cost comparison email (AUTH/2948/3/17)

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Key facts

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Case	AUTH/2948/3/17
Parties	General Practitioner v Novo Nordisk
Product	Tresiba (insulin degludec)
Material	Promotional email (ref UK/TB/1116/0498)
Main issues	Permission to email; cost comparison table basis/assumptions; clarity of HbA1c claim in context
Complaint received	22 March 2017
Case completed	21 July 2017
Applicable Code year	2016
Breach findings	Clauses 7.2 and 7.3
No breach findings	Clauses 9.9 and 9.1 (and no breach on some specific 7.2/7.3 allegations)
Sanction	Undertaking received
Appeal	No appeal

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

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A general practitioner complained about a promotional email for Tresiba (insulin degludec) sent by Novo Nordisk (ref UK/TB/1116/0498).
The email opened with claims including “Get HbA1c DOWN with CONTROL” and “NEW LOWER PRICE”, and described a 35% price reduction.
It included the line “You might be surprised by Tresiba treatment cost (Type 2 Basal only)”.
The email cited dose statements (eg, 10% lower dose for Tresiba vs insulin glargine U100; 17% higher dose for insulin glargine U300 vs U100) and presented a prominent table comparing illustrative dose and monthly/annual costs for Tresiba U100/U200, Toujeo, Lantus and Abasaglar.
The complainant alleged: (a) they had not given permission to receive promotional emails; (b) the cost comparison chart was not evidence-based because there were no direct head-to-head trials across all products shown; (c) the “Type 2 Basal only” framing conflicted with references including type 1 data; and (d) “Successful reductions in HbA1c” was unclear and potentially comparative.

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No breach of Clause 9.9 (permission to email): the complainant remained anonymous and there was no evidence before the Panel to establish whether permission had or had not been given.
Breach of Clauses 7.2 and 7.3: the cost comparison table was misleading because the assumptions/basis for the comparison were not sufficiently complete or prominent.
Breach of Clauses 7.2 and 7.3: the claim “Successful reductions in HbA1c” was not sufficiently clear in context and could be read as comparative.
No breach of Clause 9.1 (high standards): on balance, the Panel did not consider Novo Nordisk had failed to maintain high standards.
No appeal (Appeal hearing: No appeal).

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