Vifor corporate website: non-black black triangle symbol and no separation of public vs HCP content

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Key facts

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Case number	AUTH/3238/8/19
Case reference	AUTH/3238/8/19 (Anonymous v Vifor)
Complainant	Anonymous, non-contactable individual describing themself as a “concerned UK health professional”
Respondent/company	Vifor Pharma UK Limited
Product(s)	Ferinject (ferric carboxymaltose); Venofer (iron sucrose (iron (III)-hydroxide sucrose complex)); Velphoro (sucroferric oxyhydroxide)
Material/channel	Corporate website (product webpages; downloadable documents/leaflets)
Key issue	Inverted black triangle symbol displayed in non-black colours on product pages; public and HCP information presented together without separation on a website considered promotional overall
Dates (received/completed if stated)	Complaint received 12 August 2019; Case completed 26 March 2020
Appeal	Not stated
Code year	Not stated
Breaches/clauses	Clause 4.10; Clause 28.1
Sanctions	No explicit additional sanctions stated beyond the required undertaking/corrective actions described in the report

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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, non-contactable individual describing themself as a “concerned UK health professional” complained about Vifor Pharma UK Limited’s corporate website pages for IV irons.
The complainant alleged the inverted equilateral triangle symbols on product webpages were shown in different colours (blue, grey, or white) rather than black, including on the Ferinject page and similarly for Venofer and Velphoro.
The complainant also said it was unclear whether the website was intended for the public or health professionals because it included links to download leaflets for patients and for clinicians.
Vifor said it deactivated the corporate site immediately after being informed of the complaint and removed all brand information from the site.
Vifor stated the site had included the correct black triangle until late June and that the issue appeared to occur when a website update was uploaded incorrectly; it said it was investigating root cause and would amend its internal approval process.
On the Ferinject webpage, Vifor provided five downloadable UK documents: four were described by Vifor as non-promotional risk management materials requested by EMA/MHRA (including an Article 31 letter dated 31 October 2013, a “Dear Dr” letter dated January 2015, and IV iron leaflets for clinicians and patients). The fifth was a Scottish Medicines Consortium (SMC) document (2011) assessing Ferinject and stating it was accepted for restricted use in NHS Scotland.
The Panel considered the SMC document, while non-promotional per se, had been used for a promotional purpose because it was placed by Vifor on its corporate website and contained claims for Ferinject; overall, the Panel considered the website was promotional.

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Outcome

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Breach of Clause 4.10 was ruled (as acknowledged by Vifor) because the product webpages were considered promotional and the inverted black triangle symbol was not shown in black.
Breach of Clause 28.1 was ruled (as acknowledged by Vifor) because the website presented promotional information for health professionals and information for the public together, without clear separation and identification of intended audience.
The Panel noted Vifor had deactivated the website when informed of the complaint and removed all brand information from the site.

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