AUTH/3442/12/20: Complainant v GlaxoSmithKline (LinkedIn pipeline trial posts) – No breach | PMCPA Case

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Key facts

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Case number	AUTH/3442/12/20
Company	GlaxoSmithKline UK Limited
Complainant	Concerned health professional
Channel	LinkedIn (corporate account; one post was an enhanced/paid campaign)
Issue alleged	Promotion to the public of unlicensed products (RSV candidate vaccine; Covid-19 antibody treatment)
Products/subjects	RSV candidate vaccine (Phase 3 trial announcement); GSK/Vir Covid-19 antibody treatment (Phase 3 trial announcement)
Applicable Code year	2019
Clauses considered	2, 9.1, 26.1
Panel decision	No breach
Key reasoning	On a narrow technical point, the items were not classified as prescription only medicines at the time; overall, posts were not considered promotional on the evidence available; links treated as part of the post and were reviewed for context.
Complaint received	19 December 2020
Case completed	2 September 2021
Appeal	No appeal

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

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What happened

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A concerned health professional complained about two posts on GlaxoSmithKline’s corporate LinkedIn account.
Post 1 announced the start of a Phase 3 clinical trial for an RSV candidate vaccine, with wording such as “if successful” and “could help protect babies… from birth thanks to maternal immunisation”, plus an executive quote about “advancing our portfolio of RSV vaccine candidates…”.
Post 2 announced the start of an NIH ACTIV Phase 3 trial of a GSK/Vir Biotechnology Covid-19 antibody treatment in hospitalised adults, invited readers to “learn more” via a link, and included an executive quote about developing solutions “from prevention through treatment”.
The complainant alleged the RSV post promoted a new product to the public before licence, and that the Covid-19 post suggested this was an ongoing decision to promote to the public.
GSK said both posts were corporate reputation communications intended for the “informed public”, were factual/non-promotional, contained no efficacy claims, and were reviewed by experienced ABPI signatories (GMC-registered physicians).
The RSV post was an “enhanced post” supported by a paid campaign targeted to people aged 25+ with interests such as science/technology/investors/science news (i.e., not restricted to existing followers).
The Covid-19 post linked to GSK’s corporate “Our response to CoViD-19” page; the landing page discussed collaborations (eg adjuvants) and included a “Developing Covid-19 treatments” tab with high-level information and no trial results.

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Outcome

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No breach of the ABPI Code (Applicable Code year: 2019).
No breach of Clause 26.1 (on a narrow technical point: the items referred to were not classified as prescription only medicines at the time of posting).
No breach of Clause 9.1 (posts not considered promotional on the evidence available).
No breach of Clause 2 (given the above rulings).

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AUTH/3442/12/20: Complainant v GlaxoSmithKline (LinkedIn pipeline trial posts) – No breach

Key facts

What happened

Outcome

Clauses

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