AUTH/3130/12/18: Anonymous v GlaxoSmithKline – CPD meeting invite and LinkedIn post about Bexsero

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Key facts

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Case number	AUTH/3130/12/18
Parties	Anonymous v GlaxoSmithKline
Issues	CPD meeting invitation (logo/sponsorship transparency/hospitality) and LinkedIn post about Bexsero
Medicine	Bexsero (meningococcal group B vaccine)
Platform	LinkedIn (personal account of a contractor engaged by GSK Global)
Complaint received	07 December 2018
Case completed	09 August 2019
Applicable Code year	2016
Appeal	No appeal
No breach clauses	2, 9.1, 12.1, 22.1, 22.4
Breach clauses	9.1, 26.1, 26.2
Sanctions	Undertaking received

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

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An anonymous complainant raised two issues: (1) a poster/invitation for a pharmacists’ CPD meeting (asthma medication reviews and a minor illness referral service) showing a retail pharmacy group name and a GSK logo; (2) a LinkedIn post about Bexsero (meningococcal group B vaccine) shared by individuals connected to GSK.
CPD meeting invite: The retail pharmacy group advertised the invitation (with GSK logo) before GSK had confirmed sponsorship and without GSK’s approval/knowledge. The invite referenced a restaurant venue and a three-course meal.
GSK said it was approached about sponsorship in November 2018, requested details for due diligence, warned the organiser the invitation was not compliant and needed amendment, and later withdrew its sponsorship offer on the day of the meeting after learning the non-compliant invite continued to circulate. GSK did not sponsor or attend the meeting.
LinkedIn post: A contractor engaged by GSK Global shared, on a personal LinkedIn account, a post linking to an industry news article (fiercepharma.com) with wording including “Looks like another potential vaccines blockbuster!” and referencing Bexsero’s “promise against gonorrhoea” (an unlicensed indication).
GSK stated it did not post/share the article on corporate channels, did not instruct/encourage the contractor, and the contractor acted in breach of GSK policy and mandatory social media training.

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CPD meeting invite: No breach ruled for Clauses 2, 9.1, 12.1, 22.1, 22.4 (and the Panel stated Clause 9.10 was not relevant and made no ruling; Clause 22.2 had no allegation and no ruling).
LinkedIn post: Breach ruled for Clauses 26.1 (promotion of a prescription only medicine to the public), 26.2 (information made available to the public may encourage requesting a specific POM), and 9.1 (high standards not maintained).
No breach of Clause 2 was ruled for the LinkedIn issue (Panel said the circumstances did not warrant that level of censure).
Clause 11.1: the Panel did not consider there was an allegation and made no ruling.

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