Novo Nordisk: Saxenda exhibition stand at medical aesthetics conference found to breach high standards (AUTH/3333/4/20)

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Key facts

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Case number	AUTH/3333/4/20
Complainant	Anonymous individual (self-described health professional)
Company	Novo Nordisk
Medicine	Saxenda (liraglutide)
Issue	Alleged promotion of a prescription-only medicine to the public at a medical aesthetics exhibition; appropriateness/visibility of promotional stand and completeness of company’s disclosures
Event	CCR (Clinical, Cosmetic, Regenerative) medical aesthetic exhibition, London (Oct 2019)
Audience data cited	3,754 attendees; 84% health professionals; 2% press; 14% “other” (supplier, nutritionist, association, marketing/PR, receptionist/PA)
Applicable Code year	2019
Complaint received	20 April 2020
Case completed	9 December 2020
Panel decision	Breach Clauses 26.1, 9.1, 2
Appeal outcome	No breach Clauses 26.1 and 2; breach Clause 9.1 upheld
Sanctions	Undertaking received; additional sanctions not stated

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

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What happened

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An anonymous complainant (self-described health professional) attended CCR (Clinical, Cosmetic, Regenerative) medical aesthetics exhibition in London (Oct 2019) and alleged Novo Nordisk promoted the prescription-only medicine Saxenda (liraglutide) to non-health professionals/public.
The complainant alleged Saxenda leaflets were given out and that the event had “very large numbers” of attendees who were not health professionals; they later saw patients asking for Saxenda.
Novo Nordisk said CCR was aimed at health professionals; post-event data stated 3,754 attendees: 84% health professionals; 16% press/“other” (2% press; 14% “other” including supplier, nutritionist, association, marketing/PR, receptionist/PA).
Novo Nordisk said all delegates could access the exhibition area, but staff scanned barcoded badges and only discussed Saxenda with health professionals/other relevant decision makers.
The stand panel included prominent promotional claims (eg “The first GLP-1 analogue that is indicated for weight management as an adjunct to exercise” and “Help your patients WITH OBESITY get the WEIGHT REDUCTIONS they need”) and additional claims (including secondary improvements in cardiometabolic risk factors) visible to passers-by.
The Panel was concerned that the existence/content of the promotional exhibition panel was not provided until specifically requested, and that the company’s response implied only one-to-one conversations were promotional.
At appeal, further details emerged (eg updated prescribing information available on representatives’ iPads; injection pads and demonstration pens available for use). The Appeal Board criticised the quality/completeness of Novo Nordisk’s responses as “extremely poor”.

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Outcome

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Clause 26.1: Panel ruled breach (promotion of POM to the public) but Appeal Board overturned—no breach on balance, due to insufficient evidence that Saxenda was promoted to the public in the particular circumstances.
Clause 9.1: Panel ruled breach (failure to maintain high standards) and Appeal Board upheld—breach.
Clause 2: Panel ruled breach (particular censure) but Appeal Board overturned—no breach.
Sanction recorded: Undertaking received.

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Key facts

What happened

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Clauses

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