Sanofi Toujeo Coach webinar invite briefing: copy/paste template and tracking invites (AUTH/3454/1/21)

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Key facts

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Case number	AUTH/3454/1/21
Complainant	Anonymous, non-contactable employee (described themselves as a Sanofi representative)
Company	Sanofi
Material/activity	Briefing materials for representatives; certified webinar invitation email and certified briefing document for Toujeo Coach webinars
Medicine/programme	Toujeo (insulin glargine 300 units/ml) / Toujeo Coach patient support programme
Main allegations	Copy/paste sending could cause errors/missing data; tracking invites could pressure non-compliant outreach; possible uncompliant reminder emails; concerns ignored/culture
Applicable Code year	2019
Clauses considered	9.1, 14.1, 15.2, 15.9
Panel decision	No breach of the Code
Complaint received	20 January 2021
Case completed	8 September 2021
Appeal	No appeal

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

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An anonymous, non-contactable complainant (describing themselves as a Sanofi representative) raised concerns about briefing materials for Toujeo Coach, a patient support programme for adults prescribed Toujeo.
The complaint focused on an approved webinar invitation email to health professionals and a follow-up internal email about an “error” with using the invitation.
Representatives were instructed that if they could not reuse the invite template, they should copy and paste the certified content and send it themselves; the complainant alleged this could lead to errors or missing data.
Representatives were asked to track how many invites they sent and report back; the complainant alleged this could create pressure to send to as many HCPs as possible, whether compliant or not.
The complainant alleged a named colleague may have sent “uncompliant reminder emails”.
The complainant also raised concerns about the culture implied by these actions and that their concerns had been ignored.

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No breach of the Code was found.
No breach of Clauses 14.1 and 15.9 (certification/briefing materials): the copy/paste instruction was consistent with the certified briefing and there was no evidence it led to errors or missing certified content.
No breach of Clause 15.9 (pressure/advocating non-compliant action): requesting numbers of invites sent was not considered unreasonable and there was no evidence of targets or pressure to invite inappropriately.
No breach of Clause 15.2 (high standard of ethical conduct by representatives): the complainant did not establish, on the balance of probabilities, that reminder emails were sent or were non-compliant.
No breach of Clause 9.1 (high standards): based on the evidence, the Panel did not consider Sanofi failed to maintain high standards.

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