Bayer: Xarelto public website invitation to contact medical information breached high standards (AUTH/3270/10/19)

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Key facts

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Case number	AUTH/3270/10/19
Company	Bayer
Product	Xarelto (rivaroxaban)
Channel/material	Website (Xarelto-info.co.uk) with separate sections for UK healthcare professionals and patients/public
Complainant	Concerned UK health professional
Complaint received	25 October 2019
Case completed	5 August 2020
Applicable Code year	2019
Breach clauses	9.1
No breach clauses	2, 26.1, 26.2, 28.1
Key wording at issue	“For more information on Xarelto, please contact [medical information email address]” (on patient/public webpage)
Sanctions	Undertaking received; additional sanctions not stated
Appeal	No appeal

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

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A UK health professional complained about Bayer’s UK website for Xarelto (rivaroxaban), a prescription only medicine.
The landing page had two routes: one for UK healthcare professionals and one for patients/public.
The complainant alleged the site promoted Xarelto to the public and encouraged patients/public to contact Bayer medical information about the medicine.
The patient/public section included disease information (atrial fibrillation and venous thromboembolism), links to NICE guidance and patient organisations/charities, and links to the Xarelto SPC and PIL.
The patient/public page also included a statement: “For more information on Xarelto, please contact [medical information email address]”.

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No breach of Clauses 26.1 and 26.2: the Panel did not find evidence that the website promoted Xarelto to the public or encouraged them to ask a health professional to prescribe it.
No breach of Clause 28.1: the health professional and patient/public sections were clearly separated and audiences identified.
Breach of Clause 9.1: inviting members of the public to contact the company for more information about Xarelto was considered to solicit enquiries about a prescription only medicine and went beyond permitted reference/reactive information.
No breach of Clause 2: the Panel did not consider the circumstances warranted particular censure.

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