Gedeon Richter website: missing generic names on HCP resource centre (AUTH/3273/10/19)

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Key facts

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Case	AUTH/3273/10/19
Parties	Complainant v Gedeon Richter
Material	Company website (Richter Resource Centre)
Complaint received	28 October 2019
Case completed	24 April 2020
Applicable Code year	2019
Products mentioned	Esmya (ulipristal acetate), Levosert (levonorgestrel), Bemfola (follitropin alfa)
Main issue(s)	Alleged disguised promotion; alleged promotion to the public; missing non-proprietary (generic) names next to brand names
Breach clauses	Clause 4.3; Clause 9.1
No breach clauses	Clause 2; Clause 12.1; Clause 26.1; Clause 28.1
Sanctions	Undertaking received
Appeal	No appeal

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

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A UK health professional complained about the online “Gedeon Richter Resource Centre”, described as providing training for health professionals and resources to use with patients.
The complainant saw links to prescribing information for Esmya, Levosert and Bemfola and alleged the site was promotional “albeit disguised”.
The complainant alleged the generic (non-proprietary) names were missing next to the brand names (including on the Resources tab).
The complainant also alleged there was nothing to stop the public using the website, so it promoted prescription-only medicines to the public.
Gedeon Richter said the site was promotional with educational content, intended for health professionals, promoted to HCPs in a targeted way (eg leavepieces), and did not link from the UK corporate website.
Entry to the site asked users to select “I am a healthcare professional” or “I am a member of the public”; public users were directed to a non-promotional site (fibroidsconnect.co.uk) with no product mention.
Gedeon Richter acknowledged the lack of generic names next to brand names “clearly needed to be corrected”, took the website down, and said it would not be reactivated until changes were made.

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No breach of Clause 12.1 (disguised promotion): the Panel considered HCPs would understand the material was developed by Gedeon Richter for HCPs and would likely assume it was promotional; it was not “disguised”.
Breach of Clause 4.3: brand names appeared without the required non-proprietary names on the homepage and resources page of the HCP section.
No breach of Clause 28.1: access to the HCP section was restricted in line with the Code and intended audience was clear.
No breach of Clause 26.1: the complainant did not show, on the balance of probabilities, that the HCP section constituted promotion of POMs to the public.
Breach of Clause 9.1: failure to include non-proprietary names meant Gedeon Richter failed to maintain high standards.
No breach of Clause 2: the Panel did not consider the circumstances warranted this particular censure.

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