AstraZeneca voluntary admission: employee re-tweeted product-related tweets about Forxiga and Lynparza from a personal Twitter account

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Key facts

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Case number	AUTH/3248/9/19
Case reference	Voluntary admission by AstraZeneca
Complainant	Treated as a complaint under Paragraph 5.6 of the Constitution and Procedure following AstraZeneca’s voluntary admission
Respondent/company	AstraZeneca UK Limited
Product(s)	Forxiga (dapagliflozin); Lynparza (olaparib)
Material/channel	Personal Twitter account re-tweets (product-related)
Key issue	Re-tweeting product-related content on personal social media: unlicensed promotion, advertising POMs to the public, and lack of certification; high standards
Dates (received/completed if stated)	Complaint received 30 September 2019; case completed 7 February 2020
Appeal	Not stated
Code year	Not stated
Breaches/clauses	Clauses 3.2, 9.1, 14.3, 26.1
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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AstraZeneca UK Limited made a voluntary admission that a UK-based employee used his/her personal Twitter account to re-tweet nine tweets about Forxiga (dapagliflozin) and one tweet about Lynparza (olaparib).
The nine Forxiga-related tweets were originally posted by health professionals after presentation of top-line DAPA-HF study results at the European Society of Cardiology (ESC) Congress (31 August – 4 September 2019).
The DAPA-HF content related to dapagliflozin use in heart failure; the data presented were not within Forxiga’s licensed indications at the time.
The re-tweets were positive about dapagliflozin results in heart failure in patients with or without diabetes and included clinical-trial slides/details.
The employee’s Twitter followers included both health professionals and members of the public.
The re-tweets were deleted in early September 2019 after the employee was asked to remove them.
A further re-tweet on the same account about Lynparza (“AstraZeneca’s Lynparza gets EU nod as first-line ovarian cancer maintenance treatment”) was identified and deleted later that day (AstraZeneca stated it was alerted to this on 12 September; it was deleted later that day).
AstraZeneca stated it reminded employees about its social media policy and reinforced that product-related content (including study results) was not allowed on employees’ personal social media channels.
The employee had been trained on the Global Standard: Social Media Personal Use in January 2018; updated versions (February 2018 and August 2019) had not been “read and signed” by the employee due to an automated update issue, although the employee was alerted to updated guidance via other channels.
The Panel noted company announcements in August 2019 that appeared to encourage employees to post certain work-related content on personal social media, which the Panel considered could have contributed to confusion about what was permitted.

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Outcome

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The Panel ruled that the Forxiga-related re-tweets promoted Forxiga for an unlicensed indication and advertised a prescription only medicine to the public.
The Panel ruled that the Forxiga-related re-tweets had not been certified prior to use.
The Panel ruled that the Lynparza re-tweet advertised a prescription only medicine to the public and had not been certified prior to use.
The Panel considered the Lynparza re-tweet promoted an unlicensed indication (the Panel noted the ovarian cancer indications appeared to be second line, whereas the re-tweet referred to first-line maintenance treatment).
The Panel ruled that high standards had not been maintained by AstraZeneca.
Complaint received: 30 September 2019.
Case completed: 7 February 2020.

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Clauses

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Clause 3.2 (promotion of a medicine for an unlicensed indication): breached (Forxiga re-tweets; Lynparza re-tweet).
Clause 26.1 (advertising prescription only medicines to the public): breached (Forxiga re-tweets; Lynparza re-tweet).
Clause 14.3 (certification of material): breached (Forxiga re-tweets; Lynparza re-tweet).
Clause 9.1 (high standards): breached.

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Key facts

What happened

Outcome

Clauses

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