GSK breached ABPI Code after Avamys digital banner showed illegible generic name (AUTH/3328/4/20)

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Key facts

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Case number	AUTH/3328/4/20
Complainant	Anonymous (concerned UK health professional)
Company	GlaxoSmithKline
Product	Avamys (fluticasone furoate nasal spray)
Material	Dynamic digital banner advertisement on Pulse website
Main issue	Illegibility of the non-proprietary (generic) name adjacent to the brand name
Applicable Code year	2019
Breach clauses	Clause 4.3; Clause 9.1
Sanctions	Undertaking received; Additional sanctions: Not stated
Complaint received	02 April 2020
Case completed	10 July 2020
Appeal	No appeal
Notable process point	HTML file review step (required by company procedure) was omitted; Panel also queried whether different sizes/layouts should be separately certified with unique reference numbers

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

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An anonymous individual (described as a concerned UK health professional) complained about a dynamic digital banner advertisement for Avamys on the Pulse website (pulsetoday.co.uk).
The complainant said the ad was close to illegible and that the generic (non-proprietary) name under the brand name could not be read, even when zooming in.
The ad was a rotating banner (five frames; each frame visible for four seconds; total 20 seconds) and existed in multiple sizes, including 300x250 (the version complained about).
GSK’s certified final-form PDF showed the non-proprietary name present and legible, but GSK’s investigation found the HTML file version had the non-proprietary name small and difficult to read (including on 300x250 and 300x50).
GSK’s internal process required review of two file formats before approval (image files at 100% magnification and HTML in a staging environment). The HTML review step had been omitted.
The banner ran on various websites from 23 Aug–23 Sep 2019, and again from 29 Jan–3 Apr 2020 (including Pulse). It was removed from circulation as part of discontinuation completed on 3 Apr 2020.
GSK also identified two other Avamys banner ads with similar legibility issues; these were addressed separately as a voluntary admission in another case (AUTH/3341/5/20).

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Breach found: the non-proprietary name was not readily readable in the electronic advertisement.
Breach found: high standards were not maintained because required internal approval steps (HTML review) were not followed.
No appeal.

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