AUTH/3292/12/19: Employee complaint about ECR ‘round table’ dinner and compliance culture at GE Healthcare (No breach)

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Key facts

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Case	AUTH/3292/12/19
Complainant	Employee
Company	GE Healthcare
Issue	Arrangements for a meeting and company culture
Meeting	“Oncology CT Imaging Round Table” (round table meeting with dinner)
Date / location	27 February 2019, Vienna (during ECR 2019)
Attendees	Radiologists who were ECR delegates; none were UK health professionals or other relevant decision makers; two UK-based global staff attended
Hospitality cost	€60 per attendee including drinks
Panel view on scope	UK Code applied in the circumstances
Applicable Code year	2019
Clauses considered	2, 9.1, 14.2, 15.9, 22.1, 22.2
Outcome	No breach
Complaint received	20 December 2019
Case completed	12 February 2021
Appeal	No appeal

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

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What happened

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A GE Healthcare employee complained about arrangements for an event described as an “Oncology CT Imaging Round Table” held on 27 February 2019 during the European Society of Radiology (ECR) conference in Vienna.
The complainant alleged the “round table” was not a genuine meeting but “just a dinner held in order to gain the favour of influential radiologists”, with no agenda, slides or discussion, and that guests ate in a restaurant alongside other customers.
The complainant alleged they rejected the meeting but a more senior employee approved it anyway (GE Healthcare did not comment on whether it was approved over the complainant’s head).
The complainant also made broader allegations about company culture: pressure on medical staff to push ethical limits; being told the Code had “Fifty shades of grey” and to find “opportunities within the loopholes”; and that sales representatives were encouraged to prompt discussions with medical affairs because medical affairs could speak about off-label use.
GE Healthcare denied the allegations, stated the meeting had a scientific/educational purpose, said it was held in a private reservable booth (not a restaurant), and said the cost was €60 per attendee including drinks (within the Austrian PHARMIG limit of €75).
GE Healthcare argued the meeting was outside the scope of the UK Code because it was outside the UK and no UK health professionals or other relevant decision makers were invited or attended; however, two UK-based global staff attended.
The Panel first considered whether the UK Code applied and concluded it did, given the UK nexus (UK-based global leadership and the Code’s applicability principles for UK-located companies operating in Europe).

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Outcome

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No breach of the ABPI Code was ruled.
The Panel ruled the UK Code applied to the meeting in Vienna in the circumstances of this case.
No breach was found in relation to the meeting arrangements (including certification), the allegation that it was merely a dinner to gain favour, the level of hospitality, the off-label prompting allegation, or the broader culture/pressure allegations (insufficient evidence on balance of probabilities).
The Panel noted concerns about aspects of the meeting (eg lack of slides, informality during dinner, and potential confusion between promotional vs non-promotional formats), but stated there was no allegation framed on that specific point.

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Key facts

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