LEO Pharma: UK employees’ LinkedIn ‘likes’ brought global posts into scope, triggering certification, PI and pre-licence promotion breaches (AUTH/3428/11/20)

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Key facts

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Field	Details
Case number	AUTH/3428/11/20
Parties	Anonymous, contactable complainant v LEO
Channel	LinkedIn (global corporate page; UK employees’ engagement)
Complaint received	11 November 2020
Case completed	12 January 2022
Applicable Code year	2019
Core issues	Employee ‘likes’ treated as proactive dissemination; uncertified disease awareness (Clause 14.3); uncertified promotion (Clause 14.1); missing prescribing info/date; misleading safety claim; promotion prior to marketing authorisation; promotion of POM to public (in one post).
Medicines/subjects referenced	Enstilar (PSO-LONG trial); tralokinumab (Phase 3 data referenced in “#PRESS” posts); disease awareness (psoriasis/eczema); pipeline IL-17A PPI compound (no breach for pre-licence promotion in Post D).
Sanctions applied	Undertaking received; Additional sanctions: Advertisement

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

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An anonymous, contactable complainant challenged LEO Pharma’s use of LinkedIn, focusing on a global corporate page (“Leo Pharmaceuticals Ballerup DK”) that UK audiences were directed to from the UK corporate website.
The complainant alleged UK employees’ LinkedIn reactions (eg ‘likes’, ‘support’, ‘celebrate’) effectively shared/disseminated posts to their connections, potentially including the public.
Fourteen posts (A–N) were cited, including disease awareness posts (psoriasis/eczema), congress/symposium content, pipeline content, and “#PRESS” posts linking to media/press release pages.
The Panel/Appeal Board considered that UK employees’ engagement with posts, on the balance of probabilities, proactively disseminated the material to their connections and brought the posts (and associated videos/links) within the scope of the Code.
Key problem areas included: (a) disease awareness content not certified as required; (b) promotional content for a POM (Enstilar) disseminated without certification/prescribing information/date; (c) a misleading safety impression (“No cases of skin atrophy”); and (d) dissemination of Phase 3 press-release style content about tralokinumab prior to marketing authorisation.
The Panel criticised LEO’s social media governance as unclear/contradictory (eg 2013 policy said product posts were “strongly discouraged” while a 2018 UK/IE card encouraged staff to “like and engage with our social media posts”).

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Breach findings upheld on appeal for: Post A (Clause 14.3), Post C (Clauses 14.1, 4.1, 4.8, 7.2, 7.9, 3.2), Post H (Clause 14.3), Post L (Clause 14.1), Post N (Clause 14.1), and overall Clause 2.
Clause 2 breach (particular censure) was upheld due to multiple breaches including promotion prior to marketing authorisation and inadequate/unclear employee guidance.
Some allegations were not upheld (eg no breach for certain posts regarding promotion to the public, black triangle, teaser advertising, or where burden of proof not met for promotional status/certification).

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