Diurnal: “Products and Pipeline” webpage ruled promotional—pre-licence pipeline promotion and missing PI

📊

Key facts

⌄

Case	AUTH/3274/10/19
Parties	Complainant v Diurnal
Issue	Promotion of pipeline products on an HCP-directed corporate website page; missing prescribing information and non-proprietary name for a licensed product on a promotional page
Channel	Corporate website (health professionals section)
Material	Table headed “Diurnal’s drug-development pipeline – Europe” within “Products and Pipeline” / “Clinical Trials”
Licensed product referenced	Alkindi (hydrocortisone granules in capsules for opening), licensed 2018 for paediatric adrenal insufficiency
Panel view	Overall impression was promotional; implied claims (“effective, high quality”) and inclusion of indications/timelines promoted unlicensed medicines; PI and non-proprietary name missing for Alkindi on that page
Breach clauses	Clause 3.1; Clause 4.1; Clause 4.3; Clause 9.1; Clause 2
Sanctions	Undertaking received; Additional sanctions: Advertisement
Complaint received	24 October 2019
Case completed	18 February 2020
Applicable Code year	2019
Appeal	No appeal

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

🤖

Got a question about this case?

Ask one of our 13 specialist ABPI advisors — instant answers, 24/7.

Ask AskAnzal AI

🎬 Expert Video Walkthrough

🎬

Video walkthrough — coming for members

Subscribe now and get expert video analysis for every case as we publish them.

Subscribe — from £299/yr

📋

⌄

A “concerned UK health professional” complained about a Diurnal corporate website page in the health professionals section.
The page combined “Products and Pipeline” content and included a table titled “Diurnal’s drug-development pipeline – Europe” within a “Clinical Trials” section.
The table listed five products: one licensed product (Alkindi, licensed in 2018 for paediatric adrenal insufficiency) and four pipeline products with indications, clinical trial status and expected approval dates (2021, 2023, and TBC).
Introductory wording included: “Diurnal is dedicated to bringing effective, high quality products…” which the Panel considered implied the listed medicines were effective and high quality.
For Alkindi on that page, there was no link to prescribing information and the non-proprietary name was not provided.

⚖️

⌄

The Panel ruled the webpage was promotional and designed to elicit interest in both the licensed medicine and pipeline products.
Information about the unlicensed medicines constituted promotion of unlicensed medicines.
For Alkindi, the page was promotional but did not include required prescribing information (or a clear, prominent single-click link) and did not include the non-proprietary name.
The Panel ruled that high standards had not been maintained.
The Panel ruled a Clause 2 breach, citing poor understanding of the Code and that the conduct fell short of competent care; promotion prior to marketing authorisation is an activity likely to be ruled in breach of Clause 2.

🔒

Members get the complete breakdown — Clauses, Sanction, Signatory Lens, Audit checklist, and 3 Key Questions.

Best value

£249/year

Annual — save £99

£29/mo

Monthly

Join Now — Instant Access