GSK breached ABPI Code after Avamys banner ad generic name was not readily readable (AUTH/3328/4/20)

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Key facts

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Case	AUTH/3328/4/20
Complainant	Anonymous (concerned UK health professional)
Company	GlaxoSmithKline
Product	Avamys (fluticasone furoate nasal spray)
Channel	Dynamic digital banner advertisement on Pulse (pulsetoday.co.uk)
Issue	Non-proprietary (generic) name under brand name not readily readable in the served HTML banner
Ad details	Five rotating frames; 20 seconds total; complained-of size 300x250; job ref PM-GB-FLF-BNNR-190003
Key process failure	HTML file in staging environment not reviewed as required by company procedure
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

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

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An anonymous individual (a concerned UK health professional) complained about a dynamic digital banner advertisement for Avamys (fluticasone furoate nasal spray) on the Pulse website (pulsetoday.co.uk).
The complainant said the ad was close to illegible and 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, 20 seconds total) and the complained-of size was 300x250.
GSK’s certified “final form pdf” showed the non-proprietary name as present and legible, but GSK’s investigation found the HTML file used for the live banner displayed the non-proprietary name as small and difficult to read (including on 300x250 and 300x50 versions).
GSK’s internal process required review of two file formats before approval (image files at 100% magnification and the 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’s wider review of Avamys banners approved in 2019/20 identified two other banner ads with similar legibility issues; these were withdrawn and the 2020 Avamys digital campaign was put on hold.

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Breach of Clause 4.3 was ruled (as acknowledged by GSK) because the non-proprietary name was not in a size such that it was readily readable in the electronic advertisement.
Breach of Clause 9.1 was ruled (as acknowledged by GSK) because the required HTML file review was not performed, meaning high standards were not maintained.
The Panel queried whether certifying multiple sizes/layouts under one job bag reference aligned with guidance that different sizes/layouts should be separately certified with unique reference numbers (no separate breach stated in this case report).
GSK’s submission about two additional Avamys banner ads with similar issues was taken up as a voluntary admission in a separate case (AUTH/3341/5/20).

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