Sanofi: Praluent advertorial on HSJ website found not to be promotion to the public (AUTH/3142/1/19)

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Key facts

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Case	AUTH/3142/1/19
Company	Sanofi
Complainant	Anonymous individual (professional status unknown)
Material	Online advertisement/advertorial on HSJ website
Medicine	Praluent (alirocumab)
Headline/title	“Advertorial: PCSK9 inhibitors – Recognising innovation in cholesterol treatment to help address a UK health burden”
Date of piece	25 June 2018
Complaint received	07 January 2019
Case completed	24 April 2019
Applicable Code year	2019 (Authority referenced requirements of Clauses 9.1, 11.1, 26.1 and 26.2 of the 2016 Code)
Clauses considered	9.1, 11.1, 26.1, 26.2
Outcome	No breach
Appeal	No appeal
Notes on references/links	Panel stated that if links are used in advertisements then they should work; substantiation must be provided on request, and on the information available there had been no request.

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

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An anonymous complainant (professional status unknown) challenged an online advertisement/“advertorial” for Praluent (alirocumab) placed by Sanofi on the HSJ (Health Service Journal) website.
The advertorial was titled: “Advertorial: PCSK9 inhibitors – Recognising innovation in cholesterol treatment to help address a UK health burden” and was dated 25 June 2018.
The complainant said they were surprised to see prescribing-related information in an online journal and argued the HSJ website was not suitable because members of the public could subscribe.
The complainant queried whether Sanofi had permission to create hyperlinks to third-party sites (eg NICE, British Heart Foundation) and said some reference links could not be accessed.
The complainant felt the content focused on clinical aspects more appropriate for doctors than HSJ’s mixed readership.
Sanofi responded that HSJ is aimed at “Healthcare Leaders” and provided readership statistics (eg commissioners, healthcare providers, commissioning roles) to support that it was directed to health professionals and other relevant decision makers.

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No breach of the Code.
The Panel found the advertorial was sufficiently tailored to the HSJ audience and could reasonably be assumed to be of interest to that audience (no breach of Clause 11.1).
The Panel did not consider the HSJ website placement to be advertising to the public (no breach of Clauses 26.1 and 26.2).
Given the above, the Panel ruled no failure to maintain high standards (no breach of Clause 9.1).
The Panel commented that if hyperlinks are used in advertisements, they should work; however, substantiation is required to be provided on request and, on the information available, there had been no request.

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