LEO Pharma: employee complaint about HCP sponsorship and hospitality; breach found for cross‑border RBMs’ ABPI exam status (AUTH/3267/10/19)

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Key facts

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Case number	AUTH/3267/10/19
Complainant	Anonymous, non-contactable individual (appeared to be a current employee)
Company	LEO Pharma
Issue area	Sponsorship of health professionals and staff training
Complaint received	23 October 2019
Case completed	29 January 2021
Applicable Code year	2019
Appeal	No appeal
Breach clauses	Clause 16.3
No breach clauses	Clause 2; Clause 9.1; Clause 16.1; Clause 22.1; Clause 22.2
Sanctions	Undertaking received; Additional sanctions: Not stated
Panel highlights	Burden of proof not met for hospitality/bribery allegations; concern noted about non-itemised meal documentation and missing congress locations; RBMs based in Republic of Ireland working in the UK required an appropriate (ABPI-recognised) exam for UK promotional activity.

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

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An anonymous, non-contactable individual (appearing to be a current employee) complained about LEO Pharma’s promotional practices.
Allegations included: the same HCPs being invited to international congresses year after year; hospitality including large drinks bills; and that repeated all-expenses-paid trips could be seen as an incentive to prescribe.
The complainant also alleged LEO sponsored HCPs to attend meetings on request and (until recently) paid expenses into doctors’ personal bank accounts, raising concerns about transparency and potential bribery.
The complainant further alleged sales managers had limited compliance knowledge and questioned whether they were trained and had passed the ABPI examination.
LEO responded with SOPs and process descriptions for reactive and proactive sponsorship, including use of agreements, receipt-based reimbursement (historically), and later vendor-booked travel/accommodation.
LEO explained that “sales managers” were Regional Business Managers (RBMs) in the UK and Republic of Ireland; UK RBMs had passed the ABPI exam; Republic of Ireland RBMs had passed the MRII exam and did annual ABPI Code training.

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Breach found: Clause 16.3 (RBMs based in the Republic of Ireland who worked in the UK/Northern Ireland had not taken an appropriate, mutually recognised examination required by the UK Code for that portion of their role).
No breach: Clause 2 (discredit), Clause 9.1 (high standards), Clause 16.1 (training), Clause 22.1 (hospitality must be secondary/appropriate), Clause 22.2 (meal cost limit) — largely because the complainant provided no supporting evidence and could not be contacted.
The Panel noted concerns about documentation for international congress meals (lack of itemised breakdowns; locations not provided, relevant to whether UK or host-country limits applied), but still ruled no breach of Clauses 22.1/22.2 due to lack of evidence and the burden of proof not being met.
No appeal.

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