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PMCPA Case

AUTH/3393/10/20: Anonymous v Boehringer Ingelheim — social media ads for a promotional webinar (No breach)

📅 2020 | 🖉 Dr Anzal Qurbain
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Key facts

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Case numberAUTH/3393/10/20
PartiesAnonymous v Boehringer Ingelheim Limited
IssueUse of social media to advertise meetings (promotional webinar)
PlatformsTwitter (paid advertisement); Facebook mentioned but evidence not provided; campaign also executed via Facebook and Instagram (per company)
Webinar topicBleeding risk and treatment decision-making for stroke prevention in NVAF
Medicine referenced in case backgroundPradaxa (dabigatran) (not mentioned in the ad/registration page per findings)
Applicable Code year2019
Clauses consideredClauses 2, 9.1, 12.1, 26.1
Panel decisionNo breach of the Code
Complaint received4 October 2020
Case completed19 March 2021
AppealNo appeal

Download the full case report (PDF)

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

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What happened

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  • An anonymous, non-contactable complainant (self-described health professional) complained about Boehringer Ingelheim social media activity (tweets and Facebook posts) advertising a webinar: “How should bleeding risk influence your treatment decision-making for stroke prevention in NVAF?”
  • The complainant alleged the posts were promotional meeting invites placed on public social media, lacked enough information for informed sign-up, did not state what “products” would be discussed, and that the linked page did not state it was a promotional meeting.
  • The evidence provided to the Panel included a hardcopy image of a Twitter post/advertisement stating it was “Organised by Boehringer Ingelheim; Product-related information will be discussed”, “For UK Healthcare Professionals”, and linking to “boehringerconnect.co.uk”.
  • Boehringer Ingelheim stated the item was a paid Twitter advertisement (not an organic post), targeted to likely HCPs, certified as non-promotional, and did not mention or indirectly refer to a specific medicine.
  • Boehringer Ingelheim stated the linked registration page was also non-promotional and required users to confirm they were UK health professionals and provide details (eg, workplace address or GMC number) for verification before receiving further information or access to promotional/product-related content.
  • Boehringer Ingelheim stated individuals who could not be verified as health professionals were told they could not attend and were not sent further communications that could provide access to the webinar.
  • The complainant also referred to Facebook posts, but provided no supporting evidence.
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Outcome

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  • No breach of the ABPI Code of Practice was found.
  • The Panel ruled that neither the Twitter advertisement nor the linked registration page constituted promotion of a prescription only medicine to the public.
  • The Panel ruled the promotional nature of the meeting was clear prior to registration (the ad and registration page stated it was organised by Boehringer Ingelheim and that product-related information would be discussed).
  • The Panel ruled there was no failure to maintain high standards and no evidence of bringing discredit upon or reducing confidence in the industry.
  • For Facebook, the Panel ruled the complainant had not discharged the burden of proof (no evidence provided), therefore no breach was found in relation to Facebook.
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