UCB website governance failures: inaccurate UK product list, lapsed recertification of public materials, and incorrect black triangle display (AUTH/2972/8/17)

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Key facts

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Case number	AUTH/2972/8/17
Company	UCB Pharma Ltd
Complainant	Anonymous, non-contactable (stated healthcare journalist)
Material / channel	UCB UK website (product list; therapy area educational materials; Briviact press releases)
Complaint received	21 August 2017
Case completed	19 December 2017
Applicable Code year	2016
Breach clauses	Clause 2; Clause 7.2; Clause 9.1; Clause 14.5; Clause 26.2
No breach clauses	Clause 14.3; Clause 26.3
Sanctions	Undertaking received; Advertisement
Notable remediation (as stated)	Removed referenced materials from live website; reviewing full website; identified potential root causes and reviewing internal procedures; remedial steps underway to prevent recurrence of triangle colour issue
Notes from Panel	Some eMC links did not work; published press release layout differed from examined version and therefore had not been examined in relation to the Code

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

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An anonymous, non-contactable complainant (stating they were a healthcare journalist) complained about content on the UCB Pharma Ltd UK website and provided annotated screenshots.
The website section labelled “UCB’s product list” said it was “specific to the UK” but included multiple products no longer marketed by UCB in the UK (and some links to eMC did not work).
Ten public/patient educational items in the “Therapy area” (dated Aug–Oct 2012) remained in use but had not been recertified within the required two-year interval.
Three non-promotional press releases about Briviact (brivaracetam) included a black triangle symbol; when published on the website the triangle appeared orange rather than black due to a technical/layout issue.
The complainant questioned whether anyone at UCB was checking/monitoring the website content.

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Breach: The UK product list was ruled misleading/not factual or accurate for the public audience.
Breach: Poor governance meant high standards were not maintained (including longstanding issues and non-working links noted by the Panel).
Breach: Each of the 10 educational items was not recertified within two years.
No breach: The educational materials had been originally certified in advance (Clause 14.3).
No breach: Press releases were not intended for patients taking the medicine, so Clause 26.3 did not apply.
Breach: Publishing the black triangle in the wrong colour (orange) across three press releases was inappropriate and could cause confusion; high standards not maintained.
Breach: The longstanding website governance and recertification failures (particularly for public/patient materials) brought the industry into disrepute.

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