Indivior: failure to disclose 2017 UK transfers of value on ABPI central platform (AUTH/3138/12/18)

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Key facts

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Case	AUTH/3138/12/18
Parties	Ex-employee v Indivior
Issue	Non-disclosure of transfers of value
Applicable Code year	2016
Complaint received	20 December 2018
Case completed	19 August 2019
Appeal	No appeal
Breach clauses	2; 9.1; 24.1; 24.4
No breach clauses	24.6
Core finding	Failure to publicly disclose 2017 UK transfers of value on the ABPI central platform by end of June 2018 (required due to listed non-member status from June 2017).
Sanctions applied	Undertaking received; Additional sanctions; Advertisement

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

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An ex-employee alleged Indivior did not disclose 2017 payments to health professionals, donations or sponsorships in the UK (and referenced missing historic website disclosures).
Indivior said it had documented transfers of value (ToVs) for 2015 onwards, but disclosure was the issue rather than collection/monitoring.
Indivior stated it was unaware that, from June 2017, a previous senior employee had agreed the company would become a listed non-member company, comply with the Code and accept PMCPA jurisdiction.
Because of that lack of internal awareness, Indivior did not disclose 2017 UK ToVs on the ABPI central platform by the end of June 2018 (as required for its status from June 2017).
Indivior removed its voluntarily disclosed 2015 UK ToV data (and methodological note) from its website in March 2018 while seeking to improve its disclosure page.

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Breach of Clauses 24.1 and 24.4 for failure to disclose 2017 UK ToVs on the central platform by the required deadline.
No breach of Clause 24.6 (data retention) for 2017 ToV records.
Breach of Clause 9.1 (high standards).
Breach of Clause 2 (bringing discredit upon and reducing confidence in the industry) due to lack of transparency/public disclosure.
No ruling on Clauses 24.5 and 24.10 because, as there had been no public disclosure at the time the complaint was received, the Panel considered them not relevant.
No appeal.

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