GSK LinkedIn posts about Phase 3 RSV vaccine candidate and Covid-19 antibody trial: no breach (AUTH/3442/12/20)

📅 2020 | 🖉 Dr Anzal Qurbain
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Key facts

Case numberAUTH/3442/12/20
CompanyGlaxoSmithKline UK Limited
ComplainantConcerned health professional
ChannelLinkedIn (GSK corporate account)
MaterialsTwo LinkedIn posts: (1) Phase 3 RSV candidate vaccine trial announcement (maternal immunisation); (2) NIH ACTIV Phase 3 Covid-19 antibody treatment trial announcement with link to GSK β€œOur response to CoViD-19” page
Main allegationPromotion to the public of unlicensed/new products before licence; alleged ongoing decision to promote to the public
Applicable Code year2019
Clauses consideredClause(s) 2, 9.1, 26.1
Panel decisionNo breach
Key reasoningNot necessarily unacceptable to refer generally to pipeline/pandemic work; assessed language/context/audience/overall impression; both items not classified as prescription only medicines at time of posting (Clause 26.1 not engaged on that narrow technical point); posts/link content not considered promotional on evidence available
Complaint received19 December 2020
Case completed2 September 2021
AppealNo appeal
SanctionsNone

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Reviewed by Dr Anzal Qurbain (FFPM) β€” ABPI Final Signatory

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What happened

  • A concerned health professional complained about two GlaxoSmithKline UK Limited posts on the GSK corporate LinkedIn account (over 2.5m followers at the time; later over 2.8m, including 225,000+ from the UK).
  • Post 1 announced the start of a Phase 3 clinical trial for an RSV candidate vaccine for maternal immunisation, with wording including β€œif successful” and β€œcould help protect babies”. It included an executive quote about β€œAdvancing our portfolio of RSV vaccine candidates…”
  • GSK stated the RSV post was an β€œenhanced post” supported by a paid campaign targeted to people aged 25+ with interests such as science/technology/investors/science news, to convert them to followers (i.e., not restricted to existing followers).
  • Post 2 announced an NIH ACTIV Phase 3 trial beginning with GSK and Vir Biotechnology’s Covid-19 antibody treatment in hospitalised adults, tagged for investors/media, and linked to GSK’s corporate β€œOur response to CoViD-19” webpage.
  • The complainant alleged the posts amounted to promotion to the public of new/unlicensed products and suggested it was an ongoing decision rather than an isolated error.
  • The PMCPA asked GSK to consider Clauses 2, 9.1 and 26.1 of the Code.
  • GSK responded that both posts were corporate reputation communications intended to provide factual updates and transparency about research activity; both were reviewed pre-publication by experienced ABPI signatories (GMC-registered physicians).
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Outcome

  • No breach of the Code was found.
  • No breach of Clause 26.1 (on the narrow technical point that the RSV candidate vaccine and the Covid-19 antibody treatment were not classified as prescription only medicines at the time of posting).
  • No breach of Clause 9.1 (the Panel did not consider the posts promoted unlicensed medicines to the public as alleged).
  • No breach of Clause 2 (given the above findings).
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