Lilly diabetes website: “patient” pathway held to promote POMs to the public (AUTH/3252/10/19)

📅 2019 | 🖉 Dr Anzal Qurbain
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Key facts

CaseAUTH/3252/10/19
CompanyEli Lilly & Company Limited
ComplainantAn individual who described him/herself as a concerned UK health professional
ChannelCompany diabetes website (lillydiabetes.co.uk)
Main issueAlleged promotion of prescription only medicines to the public via “patient” pathway and lack of general-public section
Complaint received7 October 2019
Case completed7 February 2020
Applicable Code year2019
Breach clauses9.1, 26.1, 28.1
No breach clauses2
SanctionsUndertaking received; additional sanctions not stated
AppealNo appeal

Download the full case report (PDF)


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

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What happened

  • A UK health professional complained about Lilly’s diabetes website (lillydiabetes.co.uk).
  • The landing page offered two choices: “I am a health professional in the UK” or “I am a patient in the UK”, with no obvious section for the general public.
  • Selecting the patient route led to an “About Lilly Diabetes” page that included nine Lilly diabetes products shown prominently by brand logo and non-proprietary name, with links to “learn more”, instructions for use and patient information leaflets.
  • Lilly said product-specific information was gated: users had to confirm they had already been prescribed the product; if not, they were redirected to Lilly’s UK corporate homepage. Links to PILs/IFUs took users to eMC.
  • The Panel considered the initial “About Lilly Diabetes” page itself was open access and contained brand/logos in a diabetes treatment context alongside promotional-style corporate language (eg “global leader”, “make life better”, “real solutions”).
  • The Panel also found it was not clear that “I am a patient in the UK” meant only patients already prescribed a specific Lilly medicine; a member of the public could reasonably select it and see content not intended for them.
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Outcome

  • Breach of Clause 26.1 (promotion/advertising of prescription only medicines to the public).
  • Breach of Clause 28.1 (internet/digital: requirement to provide information for the public where promotional material is provided, with clear separation and intended audience identified).
  • Breach of Clause 9.1 (high standards not maintained).
  • No breach of Clause 2 (Panel did not consider the circumstances warranted this particular censure).
  • No appeal.
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