Ipsen: Global LinkedIn post linking to ENGAGE press release ruled public promotion of Dysport (AUTH/3276/10/19)

📊

Key facts

⌄

Case number	AUTH/3276/10/19
Company	Ipsen
Complainant	Anonymous, non-contactable
Material	Material posted on LinkedIn (Ipsen Global feed) linking to ENGAGE press release
Medicine referenced	Dysport (clostridium botulinum type A toxin-haemagglutinin complex)
Main issue	Whether linking a positive clinical study press release on a public social platform amounted to promotion to the public; and whether the post was within scope of the UK Code
Panel scope finding	Within scope (UK-based global involvement via quote/permission contributed to the post)
Breach clauses	9.1, 26.1, 26.2
No breach clauses	2, 3.2
Sanctions	Undertaking received; Additional sanctions: Not stated
Complaint received	25 October 2019
Case completed	28 August 2020
Appeal	No appeal
Applicable Code year	2019

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

📋

⌄

An anonymous, non-contactable complainant challenged a post on the Ipsen Global LinkedIn feed that referenced “positive first results” from the ENGAGE study in spastic hemiparesis.
The post included a photo and quote from a senior global employee based in the UK, plus links to (1) the International Parkinson and Movement Disorder Society page and (2) an ENGAGE study press release.
The complainant believed a link led to an FDA paediatric approval announcement (unlicensed in the UK) and argued the post could be seen in the UK and raise false hope; Ipsen said the FDA press release was not linked and was unrelated.
Ipsen argued the post/press release were outside the UK Code because the account and posting team were based in Paris and Ipsen UK did not generate/approve/publish the post.
The Panel assessed whether the UK-based global involvement (the UK-based employee quote/participation) brought the post within scope under the Code’s internet provisions.

⚖️

⌄

The LinkedIn post and linked ENGAGE press release were ruled to be within the scope of the UK Code.
The ENGAGE press release, when linked on social media, was ruled to effectively promote Dysport to the public.
No breach was found for use of Dysport outside its licence in the ENGAGE study context (adult use was within licence).
No breach of Clause 2 was ruled (Panel said circumstances did not warrant that level of censure).

🔒

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