Pfizer: Senior employee’s LinkedIn post linking to BBC ‘vaccine judged safe’ headline breached ABPI Code

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Key facts

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Case	AUTH/3438/12/20
Company	Pfizer UK Ltd
Issue	Alleged promotion of Covid-19 vaccine on LinkedIn via a senior employee’s personal post linking to a BBC article with an unqualified “safe” headline
Platform	LinkedIn (personal account)
Post text	“So proud of the whole Pfizer team. What an amazing achievement #vaccines #proud”
Linked content	BBC article titled “Covid-19: Pfizer/BioNTech vaccine judged safe for use in UK”
Audience	~900 contacts; ~10% health professionals (included HCPs and members of the public)
Certification status	Neither the post nor the linked article was certified by Pfizer for UK distribution
Regulatory context	Temporary authorisation under Regulation 174; not a marketing authorisation; no SPC available at the time
Complaint received	4 December 2020
Post removed	10 December 2020
Case completed	8 June 2021
Applicable Code year	2019
Breach clauses	2, 7.9, 9.1
No breach clauses	7.10, 12.1, 26.1
Sanctions	Undertaking received; Additional sanctions; Advertisement
Appeal	No appeal

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

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A concerned member of the public complained about Pfizer UK employees praising MHRA’s rapid approval of the Pfizer/BioNTech Covid-19 vaccine on social media.
The complaint focused on a named senior UK employee’s personal LinkedIn post (2 December 2020): “So proud of the whole Pfizer team. What an amazing achievement #vaccines #proud”.
The post linked to a BBC News article titled: “Covid-19: Pfizer/BioNTech vaccine judged safe for use in UK”.
The employee had ~900 LinkedIn contacts; Pfizer said ~10% were health professionals (so the audience included HCPs and the public).
Neither the LinkedIn post nor the linked BBC article had been certified by Pfizer for UK distribution.
The post and link were removed on 10 December 2020 (8 days after posting).
At the time, the vaccine had temporary authorisation under Regulation 174 (Human Medicines Regulations 2012), not a marketing authorisation; no SPC was available (information was via Regulation 174 Information for Health Professionals).
Pfizer had a UK Social Media Policy (01-Dec-2019) stating social media audiences should be treated as the general public and that direct/indirect references or links to information about licensed or unlicensed medicines must be avoided; the employee had completed training (100% score) in November 2019.

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Breach of Clause 7.9 (use of “safe” without qualification via the unqualified BBC headline linked in the post).
No breach of Clause 7.10 (complainant did not substantiate exaggeration beyond the “safe” point; Panel would not make out the complaint for them).
No breach of Clause 12.1 (the promotional nature was not disguised; it was clearly a positive message by a Pfizer employee about a Pfizer medicine).
No breach of Clause 26.1 (on a narrow technical point: the vaccine had temporary authorisation and was not legally classified as a prescription only medicine, so Clause 26.1 did not apply).
Breach of Clause 9.1 (high standards not maintained due to uncertified promotional post on social media, contrary to company policy/training, prior to marketing authorisation).
Breach of Clause 2 (the conduct brought discredit upon and reduced confidence in the pharmaceutical industry; Clause 2 noted as a sign of particular censure).

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