Daiichi-Sankyo website product pages ruled promotional to the public (AUTH/3107/10/18)

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Key facts

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Case	AUTH/3107/10/18
Company	Daiichi-Sankyo
Complainant	Concerned UK health professional
Issue	Alleged promotion of POMs to the public via company website product pages
Material	Daiichi-Sankyo website page “Products > UK Products” (link provided in complaint)
Key content cited	Opening paragraph implying benefits; table listing brand/INN/indications; additional narrative for edoxaban and prasugrel; no SPC/PIL links; limited risk/benefit balance
Breach clauses	9.1, 26.1, 28.1
No breach clauses	2
Sanctions	Undertaking received; Additional sanctions: Not stated
Complaint received	29 October 2018
Case completed	22 February 2019
Appeal	No appeal
Applicable Code year	2016
Published	May 2019 Code of Practice Review

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

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A UK health professional complained that pages on Daiichi-Sankyo’s website promoted prescription-only medicines (POMs) to the public.
The complainant said the site did not separate patient and health professional areas and that the pages included generic name, brand name and indication.
The page shown from the link was headed “Daiichi-Sankyo UK Ltd” and “Products > UK Products”.
An opening paragraph stated that Daiichi-Sankyo’s products “treat and prevent serious illnesses” and “help people to live longer and have healthier lives”, then referenced its portfolio in acute coronary syndromes and atrial fibrillation.
The page listed eight “key products” with brand name, non-proprietary name and indication in a single table.
After patient-facing adverse event reporting information, the page provided additional condition/indication narrative for edoxaban (Lixiana) and prasugrel (Efient).
The edoxaban section described atrial fibrillation and stroke risk and stated edoxaban “was a blood thinner that could be used…to prevent strokes” (treated by the Panel as a claim).
There were no links to SPCs or PILs for any of the eight medicines; the content was not a fair reflection of risk/benefit.
Access to the page was not restricted to health professionals/decision makers.

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Breach of Clause 26.1 (promotion of POMs to the public).
Breach of Clause 28.1 (internet material about POMs must comply with the Code; where promotional, access should be restricted or audiences clearly separated as required).
Breach of Clause 9.1 (failure to maintain high standards).
No breach of Clause 2 (Panel did not consider the circumstances warranted particular censure).
No appeal.

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