Ipsen breached ABPI Code after employee’s LinkedIn job title referenced Cabometyx and RCC

📊

Key facts

⌄

Case number	AUTH/3410/10/20
Company	Ipsen
Product	Cabometyx (cabozantinib)
Channel	LinkedIn (employee personal account/profile)
Allegation	Advertising a POM to the public via LinkedIn job title referencing brand and indication
Key content at issue	‘[job title] Cabometyx RCC at Ipsen’ (and similar wording in ‘Experience’)
Complaint received	30 October 2020
Case completed	2 June 2021
Applicable Code year	2019
Breach clauses	Clause 9.1; Clause 26.1
Appeal	No appeal
Sanctions (as listed)	Undertaking received; Additional sanctions: Not stated
Ipsen mitigation noted	Visible ~3 hours; corrected same evening; max nine profile views that day; public profile visibility set to ‘off’ (but job title visible via browser search)

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

🤖

Got a question about this case?

Ask one of our 13 specialist ABPI advisors — instant answers, 24/7.

Ask AskAnzal AI

🎬 Expert Video Walkthrough

🎬

Video walkthrough — coming for members

Subscribe now and get expert video analysis for every case as we publish them.

Subscribe — from £299/yr

📋

⌄

A contactable complainant alleged an Ipsen employee advertised Cabometyx (cabozantinib) on LinkedIn, promoting a prescription only medicine (POM) to the public.
The employee’s LinkedIn profile showed a job title in the format: ‘[job title] Cabometyx RCC at Ipsen’, with similar wording in the ‘Experience’ section.
Ipsen said the LinkedIn account was the employee’s private account and the job title was created independently without Ipsen’s knowledge, involvement or endorsement.
Ipsen said the job title was visible for about three hours on the evening of Friday 30 October 2020 and was corrected the same evening to ‘[job title] Oncology’ after a colleague alerted the employee.
Ipsen said a maximum of nine LinkedIn members viewed the profile that day and described them as pharmaceutical industry professionals; the employee had 225 connections and no followers.
Ipsen said the employee’s public profile visibility settings were set to ‘off’, but acknowledged limited information (including job title) could be visible via an internet browser search.
The PMCPA Panel considered LinkedIn a publicly accessible social media platform and emphasised that employees should assume work-related personal LinkedIn activity is in scope of the Code unless clearly shown otherwise.

⚖️

⌄

The Panel ruled that the statement ‘[job title] Cabometyx RCC at Ipsen’ promoted a medicine because it included both the brand name and an indication.
On the balance of probabilities, a POM had been promoted to the public: breach ruled.
The Panel ruled that high standards had not been maintained because an employee did not follow company guidelines on which they had recently been trained: breach ruled.
No appeal (as per case listing).

🔒

Members get the complete breakdown — Clauses, Sanction, Signatory Lens, Audit checklist, and 3 Key Questions.

Best value

£249/year

Annual — save £99

£29/mo

Monthly

Join Now — Instant Access