Amgen: sponsored osteoporosis therapy review service challenged over third-party email linking “client product/therapy priorities” (No breach)

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Key facts

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Case	AUTH/3191/4/19
Parties	Anonymous v Amgen Limited
Issue	Sponsored osteoporosis/bone health therapy review service; allegation that third-party internal email linked reviews to “client product/therapy priorities” (commercial bias/disguised promotion)
Product mentioned	Prolia (denosumab)
Key evidence cited	Internal third-party email dated 14 August 2018 (extracts referencing “Amgen reviews” and “integrate client product/therapy priorities”)
Applicable Code year	2016
Clauses considered	Clause 2; Clause 9.1; Clause 12.1; Clause 19.2
Panel decision	No breach of Clauses 19.2, 12.1, 9.1; consequently no breach of Clause 2
Appeal	Appeal by complainants; unsuccessful (no breach upheld)
Complaint received	30 April 2019
Case completed	14 October 2020
Sanctions	None

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

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An anonymous contactable group (describing itself as GPs, NHS leaders, pharmacists, NHS patients and current staff of a named third-party provider) complained about therapy review services delivered by that third party for multiple pharma companies, including Amgen.
The Amgen-sponsored service related to bone health/osteoporosis; Amgen marketed Prolia (denosumab).
The complaint centred on an internal email (14 August 2018) from a senior employee at the third-party provider to its clinical team, which the complainants said linked therapy reviews to “client product/therapy priorities” and implied a return-on-investment mindset (“commercial bias”).
The email included: “4 of our 5 regions are currently recruiting Amgen reviews…” and a general statement: “transition and integrate client product/therapy priorities into our internal resource and schedules”.
Complainants alleged the email breached the Code (including Clause 2) and argued pharma companies are responsible for third parties acting on their behalf.
Amgen responded that the osteoporosis therapy review was a non-promotional service to support NICE guidance (CG146; QS149), with GP-led decision-making, written protocols, sponsorship disclosure, and no product-switch objective or product-specific recommendations by pharmacists.

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No breach of the Code was ruled by the Panel.
No breach findings were upheld on appeal (appeal by complainants unsuccessful).
The Panel and Appeal Board both expressed concern about the overall impression/tone of the third party’s email and stated Amgen had been “let down” by its third party, but found insufficient evidence that Amgen’s arrangements breached the Code.

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