Novo Nordisk advisory boards: high standards breach amid concerns over volume, format and embassy venue (AUTH/3115/11/18)

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Key facts

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Case	AUTH/3115/11/18
Parties	Anonymous, non-contactable complainant v Novo Nordisk
Topic	Advisory boards
Complaint received	07 November 2018
Case completed	01 April 2019
Published	May 2019 Code of Practice Review
Applicable Code year	2012
Allegations	Repeated advisory boards with same individuals; excessive transfer of value; disguised promotion; concerns about embassy venue/ambassador presence; lengthy strategic presentations; hospitality concerns
Company activity volume referenced	202 advisory board meetings (Nov 2012–Nov 2018) (complainant alleged “over 250” between 2012 and 2018)
Breach findings	Clause 9.1
No breach findings	Clause(s) 2, 12.1, 18.1, 19.1, 20.1 (2012 Code), 22.1 and 23.1
Sanctions	Undertaking received
Appeal	No appeal

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

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An anonymous, non-contactable complainant (describing themselves as a concerned health professional) alleged Novo Nordisk ran multiple advisory boards with the same individuals repeatedly over ~5 years, suggesting disguised promotion and excessive transfer of value.
The complainant referenced advisory boards held at a named embassy, with the ambassador present, and alleged senior leaders used the meetings to “sell” strategy via lengthy presentations rather than elicit insights.
Novo Nordisk stated it held 202 advisory board meetings between November 2012 and November 2018 across multiple therapy areas, with objectives ranging from clinical trials and care pathways to NHS structure, commissioning and patient experience.
Novo Nordisk said it had SOPs/guidance for advisory boards (including a 2016 guidance document), used fair market value (FMV) rates, disclosed payments, and selected advisors based on expertise (including external mapping/peer nomination refreshed every three years).
The Panel reviewed documentation and expressed concerns including: very high volume of advisory boards; lack of pre-reading for some meetings (including three of four at the embassy); agendas with a high proportion of company presentations vs discussion; and additional embassy-related concerns (presence of ambassador, staff-to-advisor ratios, number of advisors, dinner provision despite daytime schedule, and attendance by very senior company staff).

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Breach found: Clause 9.1 (high standards and suitability) in relation to advisory boards in general.
No breach found: Clause 23.1 (use of consultants – legitimate service) and consequently no breach of Clause 18.1.
No breach found: Clause 12.1 (disguised promotion).
No breach found: Clause 22.1 (meetings, hospitality and sponsorship) (noting the relevant clause was 19.1 in earlier Code years).
No breach found: Clause 2 (bringing discredit to the industry) was not considered warranted.
Panel noted the complainant provided no evidence and could not be contacted; the PMCPA is not an investigatory body and the burden of proof rests with the complainant.

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