Pfizer: UK employee’s LinkedIn ‘like’ treated as proactive dissemination and promotion of an unlicensed Covid-19 vaccine (AUTH/3422/11/20)

📊

Key facts

⌄

Case number	AUTH/3422/11/20
Company	Pfizer Limited
Complainant	A concerned UK health professional
Channel	LinkedIn (employee personal account; ‘like’ of Global Pfizer post)
Medicine/product	Pfizer/BioNTech mRNA Covid-19 vaccine candidate (unlicensed at time of activity)
Key allegation	Promotion of an unlicensed medicine; material not certified; promotion to the public
Complaint received	12 November 2020
Case completed	4 June 2021
Applicable Code year	2019
Breach clauses	3.1, 9.1, 14.1
No breach clauses	26.1
Sanctions	Undertaking received; additional sanctions not stated
Appeal	No appeal

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 UK health professional complained about a named Pfizer UK employee’s personal LinkedIn activity.
The employee had ‘liked’ a post from the Global Pfizer LinkedIn account (posted by Pfizer US) in November 2020.
The post announced interim Phase 3 efficacy results for the Pfizer/BioNTech mRNA Covid-19 vaccine candidate and described this as a critical step toward a “safe and effective vaccine”.
The ‘like’ occurred before any UK authorisation; the vaccine later received temporary emergency use authorisation on 2 December 2020 under Regulation 174 (not a marketing authorisation).
The complainant alleged: promotion to the public, lack of certification, and that the medicine was not yet licensed.
Pfizer said the employee acted contrary to UK social media policy (which prohibited interacting with Pfizer content posted outside the UK) and had completed training (100% score) in October 2019.
The Panel considered that a ‘like’ could increase visibility in connections’ feeds and appear in the employee’s activity list, amounting to proactive dissemination to UK connections.

⚖️

⌄

Breach of Clause 3.1 (promotion prior to marketing authorisation).
Breach of Clause 14.1 (promotional material not certified).
Breach of Clause 9.1 (high standards not maintained).
No breach of Clause 26.1 on a narrow technical point: at the time of the ‘like’ Pfizer did not have a prescription only medicine available; Clause 26.1 applies to prescription only medicines.
No appeal.

🔒

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