GSK breached ABPI Code after Avamys digital banner’s generic name was not readily readable (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)
Issue	Illegibility of the non-proprietary (generic) name in a digital banner advertisement
Channel	Pulse website (pulsetoday.co.uk)
Material type	Dynamic digital banner advertisement (rotating frames)
Reference	PM-GB-FLF-BNNR-190003 (300x250 version subject of complaint)
Applicable Code year	2019
Breach clauses	Clause 4.3; Clause 9.1
Complaint received	02 April 2020
Case completed	10 July 2020
Appeal	No appeal
Sanctions applied	Undertaking received

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 Pulse (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 complaint related to the 300x250 version (ref PM-GB-FLF-BNNR-190003).
GSK’s final-form PDF had been certified and showed the non-proprietary name as present and legible.
GSK investigated and found the HTML file in the job bag showed the non-proprietary name was small and difficult to read (including on the 300x250 version).
GSK’s own process required review of both image files (at 100% magnification) and HTML files in a staging environment; the HTML review step had been omitted by the final signatory.
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 campaign discontinuation (completed 3 Apr 2020).

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Breach of Clause 4.3 ruled (as acknowledged by GSK): non-proprietary name not readily readable in the electronic advertisement.
Breach of Clause 9.1 ruled (as acknowledged by GSK): failure to follow required approval checks meant high standards were not maintained.
The Panel noted (but did not rule within this case) a query about whether certifying multiple sizes under one job reference aligned with guidelines requiring different sizes/layouts to be separately certified.
GSK’s submission about two additional Avamys banner ads with similar issues (PM-GB-FLF-BNNR-190001 and PM-GB-FLF-BNNR-190002) was taken up as a voluntary admission in a separate case (AUTH/3341/5/20).

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