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PMCPA Case

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

📅 2020 | 🖉 Dr Anzal Qurbain
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Key facts

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CaseAUTH/3405/10/20
CompanyLEO
Channel / mediumGlobal YouTube channel (plus UK/IE HCP website CAThrombosis.com; references to cancerclot.info)
Complaint received25 October 2020
Case completed10 September 2021
Applicable Code year2019
AppealNo appeal
Scale of complaint60 videos complained about; 37 no prima facie case; 23 referred to Panel
Key breach drivers(1) T58 promotional symposium video referencing tinzaparin in UK without certification/mandatory info; (2) UK HCP site videos directing to uncertified patient site cancerclot.info
Medicines mentionedTinzaparin (brand name Innohep referenced in the ruling); Picato discussed in context of V60 but no breach found against LEO for that video’s presence
SanctionsUndertaking received; Additional sanctions: Not stated

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 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 without clear audience designation, and lacked required information (eg prescribing information, adverse event reporting wording, dates, and certification).
  • Group A (patient/carer disease awareness videos): cancer-associated thrombosis experiences; no specific medicine referenced.
  • Group B (4 videos): conversations between a patient ambassador (Canadian patient organisation) and a UK health professional; used on CAThrombosis.com (UK/IE HCP site, password protected). Videos included a prompt to visit cancerclot.info.
  • T58: a 2018 congress/symposium presentation by a UK pharmacist in a LEO Global symposium; it referred to tinzaparin (LEO medicine; brand name Innohep referenced in the ruling) and was accessible via the Global channel playlists.
  • U59: another congress presentation; Panel found it did not make specific reference to availability/use of tinzaparin in the UK and was out of scope.
  • V60: a 2012 video on a non-LEO YouTube channel; Panel considered it likely commissioned by LEO but found the complainant did not prove 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 majority of the challenged videos, including all Group A videos (treated as non-promotional disease awareness) and the Group B videos themselves (not shown to be promotional or publicly accessible).
  • Breach: The Panel ruled that directing UK HCPs (via Group B videos on CAThrombosis.com) to the patient-aimed global site cancerclot.info was problematic because cancerclot.info had not been certified (breach of Clause 14.3 in relation to cancerclot.info).
  • Breach: Video T58 was found to be promotional (it referred to the use of tinzaparin in the UK) and lacked certification and mandatory information for HCP promotion.
  • Breach: Overall, the breaches (T58 and the cancerclot.info direction) meant LEO failed to maintain high standards (Clause 9.1).
  • No breach of Clause 2 (no finding of bringing discredit/reducing confidence in the industry).
  • No breach of Clause 16.1 (insufficient evidence staff were not adequately trained/not conversant with the Code).
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