AUTH/3161/2/19: Employee v Leo Pharma – briefing slides on call frequency breached Clause 15.9 | PMCPA Case

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Key facts

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Case	AUTH/3161/2/19
Parties	Employee v Leo Pharma
Complaint received	19 February 2019
Case completed	18 June 2019
Applicable Code year	2016
Allegations	Over-frequent doctor visits; audits only for customers using Leo products; speaker slides not medically/legal approved; discouraging adverse event reporting; emailing customers without permission
Breach findings	Clause 15.9
No breach findings	Clauses 2, 9.1, 9.9, 14.1, 15.6, 19.1, 19.2
Sanctions	Undertaking received; Additional sanctions: Not stated
Appeal	No appeal
Core issue upheld	Internal briefing slides referred to call frequencies of 4 and 5 without defining call vs contact or reiterating Code requirements, likely to lead to a breach

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

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A named, non-contactable, current employee complained about Leo Pharma’s promotional practices.
Allegations included: encouraging representatives to visit doctors five times a year (more than 3 unsolicited visits), audits only for customers using Leo products, speaker slides not going through medical/legal approval, discouraging adverse event reporting, and emailing customers without permission.
The Panel noted the complaint provided only brief details and no supporting attachments/evidence.
On call frequency, the Panel focused on internal representative briefing material (topical dermatology customer segmentation plan slides) that referred to call frequencies of 4 and 5 but did not distinguish “calls” vs “contacts” or reiterate Code requirements.

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Breach: Clause 15.9 (briefing material advocated a course of action likely to lead to a breach of the Code).
No breach: Clauses 2, 9.1, 9.9, 14.1, 15.6, 19.1, 19.2.
The Panel found no evidence that actual call numbers breached the Code; the issue was the clarity/content of the internal briefing slides.
Other allegations (audits, speaker slides approval, adverse event reporting, emailing without permission) were not proven on the balance of probabilities.

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