GSK voluntary admission: Avamys digital banners had illegible non-proprietary name (AUTH/3341/5/20)

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Key facts

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Case	AUTH/3341/5/20
Company	GlaxoSmithKline UK Limited
Product	Avamys (fluticasone furoate nasal spray)
Issue	Non-proprietary name not readily readable in HTML files; not adjacent at first brand name appearance in online banner ads
Material type	Dynamic digital banner advertisements (multiple sizes; rotating frames; some scrolling text)
References	PM-GB-FLF-BNNR-190001; PM-GB-FLF-BNNR-190002 (related banner in prior case: PM-GB-FLF-BNNR-190003)
Where placed	Medscape UK, Doctors.net.uk, GP Notebook; later Pulse, RCNi, GP Online, Medscape UK
Key process gap	HTML file not reviewed by final signatory as required by company procedure
Applicable Code year	2019
Complaint received	01 May 2020
Completed	10 July 2020
Breach clauses	Clause 4.3; Clause 9.1
Sanctions	Undertaking received
Appeal	No appeal

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

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During a separate complaint (Case AUTH/3328/4/20), GlaxoSmithKline UK Limited (GSK) reviewed 11 Avamys banner ads approved for UK use in 2019/20 and found two additional online banner advertisements with similar issues (refs PM-GB-FLF-BNNR-190001 and PM-GB-FLF-BNNR-190002).
The issue: in the HTML files within the job bags, the non-proprietary name (fluticasone furoate) was small and difficult to read.
Although the non-proprietary name appeared under the brand name in the logo, it was not positioned at the first appearance of the brand name on the banners.
The final form PDFs were said to show the non-proprietary name as present and legible, but the HTML versions (the live digital assets) did not.
The HTML files for both banners had not been reviewed by the final signatory as required by GSK procedure.
The banners ran online (including Medscape UK, Doctors.net.uk, GP Notebook; later Pulse, RCNi, GP Online and Medscape UK) across periods in 2019 and 2020.
GSK withdrew the materials and placed the 2020 Avamys digital campaign on hold.

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