AUTH/3176/3/19: Orion Pharma – Sponsorship declarations in email and respiratory academy website | PMCPA Case

📊

Key facts

⌄

Case number	AUTH/3176/3/19
Company	Orion Pharma UK Limited
Material	Email and website (linking to an educational video hosted on a respiratory academy website)
Applicable Code year	2016
Complaint received	26 March 2019
Case completed	02 October 2019
Appeal	No appeal
Breach clauses	9.1, 9.10
No breach clauses	2, 4.1, 4.3, 4.4, 4.6, 4.8, 4.9, 12.1, 14.1
Sanctions	Undertaking received; Additional sanctions: Not stated
Core issue	Declarations of sponsorship/involvement understated Orion’s role (commissioning vs “funding”)

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

🤖

Got a question about this case?

Ask one of our 13 specialist ABPI advisors — instant answers, 24/7.

Ask AskAnzal AI

🎬 Expert Video Walkthrough

🎬

Video walkthrough — coming for members

Subscribe now and get expert video analysis for every case as we publish them.

Subscribe — from £299/yr

📋

⌄

A UK health professional complained about an Orion Pharma UK email (sent via a healthcare publication) inviting recipients to watch a video on “Medicines optimisation and the clinical challenges in respiratory care”.
The email stated: “This campaign has been produced by [a named healthcare publisher] with funding from Orion Pharma” and linked directly to a respiratory academy website sponsored by Orion (among others).
The complainant alleged the email and linked website/videos were promotional but lacked prescribing information and adverse event reporting information, and suggested the set-up resembled disguised promotion via a supposedly independent platform.
Orion said it had commissioned the publisher to design, create and market a series of KOL-led educational videos; content was educational, not product-specific, hosted in a sponsored content section, and materials were certified.

⚖️

⌄

No breach for allegations that the email, website, or the specific video were promotional requiring prescribing information/adverse event statement/date last drawn up (Clauses 4.1, 4.3, 4.4, 4.6, 4.8, 4.9).
Breach because declarations understated Orion’s involvement: Orion was more involved than “produced by publisher with funding from Orion” implied (Clauses 9.1 and 9.10).
No breach of disguised promotion (Clause 12.1) and certification (Clause 14.1).
No breach of Clause 2 (particular censure) in the circumstances.

🔒

Members get the complete breakdown — Clauses, Sanction, Signatory Lens, Audit checklist, and 3 Key Questions.

Best value

£249/year

Annual — save £99

£29/mo

Monthly

Join Now — Instant Access