AstraZeneca: LinkedIn post and employee ‘likes’ held to promote unlicensed Covid-19 vaccine (AUTH/3430/11/20)

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Key facts

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Case	AUTH/3430/11/20
Company	AstraZeneca
Issue	Promotion of unlicensed Covid-19 vaccine on LinkedIn (post + linked press release; amplified by UK employee ‘likes’)
Platform	LinkedIn
Material	LinkedIn post and link to press release “AZD1222 vaccine met primary efficacy endpoint in preventing COVID-19”
Complainant	Concerned UK health professional
Complaint received	24 November 2020
Case completed	14 December 2021
Applicable Code year	2019
Breach clauses	2, 3.1, 9.1
No breach clauses	26.1, 29
Sanctions	Undertaking received; Additional sanctions: Advertisement
Appeal	No appeal

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

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A UK health professional complained about a named AstraZeneca employee’s LinkedIn post praising a Covid-19 vaccine programme and stating it “offers new hope to nations around the world”.
The post included hashtags (eg #vaccines, #astrazeneca, #covidinnovation, #proudemployee) and linked to a global AstraZeneca press release titled “AZD1222 vaccine met primary efficacy endpoint in preventing COVID-19”.
AstraZeneca submitted the poster was a US-based global employee posting on a personal account and said the post was outside UK jurisdiction and aligned with US social media guidance.
Nine UK-based AstraZeneca employees had ‘liked’ the post; the Panel considered this likely proactively disseminated the content to their UK connections.
The Panel considered that linking to a press release on social media (vs hosting it in a media section) increased the expectation it would be read by a wider audience, including the public.
The press release contained high-level efficacy statements and prominent quotes suggesting the vaccine was effective and would have an immediate impact, with references to UK clinical trials and regulatory submissions.
The Panel noted AstraZeneca did not provide any UK-specific social media guidance in its submissions.

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Breach of Clause 3.1 (promotion of a medicine prior to the grant of its marketing authorisation) in relation to promotion of an unlicensed vaccine via the LinkedIn post and linked press release.
Breach of Clause 9.1 (high standards not maintained).
Breach of Clause 2 (bringing discredit upon, and reducing confidence in, the pharmaceutical industry) due to promotion of an unlicensed vaccine including to members of the public.
No breach of Clause 26.1 on a narrow technical point because AZD1222 was not classified as a prescription only medicine at the time (Clause 26.1 applies to POMs).
No breach of Clause 29 (no breach of undertakings from AUTH/3011/1/18 and AUTH/3248/9/19) because the matters were different; consequently no breach of Clause 2 in relation to each alleged undertaking breach.
No appeal.

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