LEO: Global YouTube content, UK scope and missing mandatory information for tinzaparin symposium video (AUTH/3405/10/20)

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Key facts

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Case number	AUTH/3405/10/20
Company	LEO
Channel / medium	Global YouTube channel (plus UK/IE website CAThrombosis.com; references to cancerclot.info)
Complaint received	25 October 2020
Case completed	10 September 2021
Applicable Code year	2019
Appeal	No appeal
Main breach findings	T58 promotional symposium video mentioning tinzaparin (Innohep) lacked certification and mandatory information; UK HCP site videos directed to uncertified patient site cancerclot.info
Medicines mentioned	Tinzaparin (brand name Innohep) (in T58)
Sanctions	Undertaking received

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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 (described as a pharmaceutical physician) complained about 60 videos featuring UK health professionals and/or UK patients on the LEO Pharma Global YouTube channel.
The Case Preparation Manager found no prima facie case for 37 videos; 23 videos were referred to the Panel.
The complainant alleged the videos were effectively aimed at UK audiences (public/patients/HCPs) without clear audience designation and lacked required information (eg prescribing information, adverse event reporting wording, dates, certification).
Group A (patient/carer disease awareness videos): patients/carers discussed cancer-associated thrombosis; no specific medicine referenced.
Group B (4 videos used on CAThrombosis.com): Canadian patient organisation videos (educational grant from Leo Canada) were also used on a UK/IE HCP website (CAThrombosis.com) behind registration; videos included on-screen text directing viewers to cancerclot.info.
T58 (“Pharmacists’ role in CAT management”): a Leo Global symposium video (EAHP 2018) publicly accessible via playlists; included a reference to tinzaparin (Leo LMWH; brand name Innohep) being used in a UK hospital.
U59: another symposium video; Panel found it did not make specific reference to availability/use of tinzaparin in the UK and was therefore out of scope.
V60: a historic video hosted on a non-LEO YouTube channel; Panel considered it likely commissioned by LEO but found insufficient evidence LEO (or a third party on its behalf) uploaded it, so LEO was not held accountable under the Code for its presence on YouTube.

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Outcome

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No breach was ruled for the Group A videos (non-promotional disease awareness; no specific medicine referenced).
No breach was ruled for the Group B videos themselves on CAThrombosis.com (complainant did not prove they were promotional or publicly accessible).
Breach was ruled because the Group B videos directed UK HCPs/patients to cancerclot.info, a patient-aimed site that had not been certified (breach of Clause 14.3 in relation to cancerclot.info).
T58 was found to be promotional (reference to use of tinzaparin in the UK) and within scope via Clause 28.2; it was not certified and lacked required information (breaches of Clauses 14.1, 4.1, 4.5, 4.6, 4.9 and 28.1).
U59: no breach (not within scope of the Code).
V60: no breach (complainant did not discharge burden of proof that LEO was accountable for the upload/presence on YouTube).
Overall: breach of Clause 9.1 (high standards) due to the breaches relating to T58 and cancerclot.info; no breach of Clause 2.

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LEO: Global YouTube content, UK scope and missing mandatory information for tinzaparin symposium video (AUTH/3405/10/20)

Key facts

What happened

Outcome

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