AUTH/3463/1/21: Lundbeck corporate website – recertification lapse upheld (Clause 14.5), other website/pipeline allegations not proven | PMCPA Case

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Key facts

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Case	AUTH/3463/1/21
Company	Lundbeck Limited
Material	Lundbeck UK corporate website (homepage and R&D page) and link to Lundbeck global site
Complainant	Anonymous, contactable; described self as a health professional
Complaint received	25 January 2021
Case completed	27 September 2021
Applicable Code year	2019
Appeal	No appeal
Breach	Clause 14.5
No breach clauses	2; 3.1; 4.1; 4.9; 9.1; 12.1; 14.1; 14.3; 26.1; 26.2; 28.1
Sanctions	Undertaking received; Additional sanctions: Not stated

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

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An anonymous, contactable complainant (self-described health professional) challenged content on Lundbeck Limited’s UK corporate website, including the homepage and an R&D page.
The homepage included a mental health video and showed a “page last modified” date (24 June 2020) while the “date of preparation”/job bag approval was December 2018.
The complainant alleged the site had not been re-approved within two years and raised concerns about suitability of R&D statements for the public/patients.
The complainant also alleged the UK R&D page linked users to Lundbeck’s global site where “pipeline” and “products” tabs could be found, potentially exposing the public to product/pipeline information (including indications) without appropriate warnings, segregation, prescribing information, or adverse event reporting.
Lundbeck said the UK site had been certified in December 2018 as a single job bag; it accepted that recertification was required because some content remained live beyond two years.
Lundbeck stated the UK-to-global link took users to a “Disclosure of clinical trial information” page marked “GLOBAL”; users were not taken directly to pipeline/products pages and would have to navigate further.

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Breach found: Clause 14.5 (material still in use not recertified within two years).
No breach: Clause 14.3 (homepage/video were certified in December 2018).
No breach: Clause 9.1 regarding the allegation that R&D page information was inappropriate for the public/patients (complainant did not substantiate why).
No breach: Allegations relating to pipeline/products access and disguised promotion were not established; Panel ruled no breach of Clauses 3.1, 12.1, 2 and others listed below in relation to those allegations.

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