Novo Nordisk: Undeclared employee shareholdings created potential conflict of interest (Saxenda) (AUTH/3173/3/19)

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Key facts

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Case	AUTH/3173/3/19
Parties	Anonymous v Novo Nordisk
Product	Saxenda (liraglutide)
Issue type	Alleged promotion to the public/online sales via third parties; alleged insider trading/competition concerns; employee conflicts of interest
Applicable Code year	2016
Complaint received	18 March 2019
Case completed	14 October 2019
Appeal	No appeal
Breach clauses	15.2
No breach clauses	1.11, 2, 9.1, 9.10, 12.1, 26.1
Clause(s) with no ruling	7.2
Sanctions	Undertaking received; Additional sanctions: Not stated

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

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What happened

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An anonymous, contactable health professional complained that Novo Nordisk and its employees were linked to companies allegedly advertising, distributing and selling Saxenda (liraglutide) directly to the public, including online sales without appropriate checks.
The complainant also alleged insider trading and that Novo Nordisk supported certain private companies (allegedly linked to an employee) in a way that disadvantaged competitors.
Novo Nordisk said it sold Saxenda only to one named wholesaler and had no influence over the supply chain beyond that wholesaler.
Novo Nordisk investigated (including using an external law firm), checked Companies House records, cross-checked named companies against known Saxenda suppliers, reviewed internal records for payments/sponsorship, and interviewed relevant employees.
The investigation identified that one representative held a shareholding in a distributor that had sold Saxenda in the same region where the representative promoted the product; the representative had not disclosed this interest to Novo Nordisk.
The investigation also identified that the representative (and family members) were shareholders in another company, and a second Novo Nordisk representative also held a small shareholding; neither employee had disclosed these interests to Novo Nordisk.
For other named companies alleged to be selling Saxenda online, Novo Nordisk submitted there was no employee link and no evidence of Novo Nordisk involvement.
Novo Nordisk disclosed it had sponsored three educational meetings for a company registered to the same address as one named entity (sponsorship in exchange for exhibition stand space), but denied any role in online sales or public promotion.

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Outcome

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Breach found: Clause 15.2 (employees failed to maintain a high standard of ethical conduct by not disclosing potential conflicts of interest).
No breach: Clause 1.11 (no evidence of non-compliance with applicable laws/regulations on insider trading/competition), Clause 2, Clause 9.1, Clause 9.10, Clause 12.1, Clause 26.1.
Clause 7.2: the Panel stated there did not appear to be a Clause 7.2 allegation and therefore it made no ruling.
No evidence was found (on the material before the Panel) that Novo Nordisk directed, acquiesced in, or was involved with alleged online sales/promotional activity to the public by third-party companies.

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Key facts

What happened

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