Sanofi breached ABPI Code after uncertified internal email to salesforce about Toujeo patient materials and digital campaigns (AUTH/3468/2/21)

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Key facts

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Case	AUTH/3468/2/21
Company	Sanofi
Complainant	Anonymous, non-contactable complainant (described themselves as a Sanofi employee)
Product	Toujeo (insulin glargine 300 units/ml solution for injection in a pre-filled pen)
Material	Email to salesforce: “Toujeo news – Patient material & Digital campaign”
Main issue	Email treated as rep briefing/instructions and not certified; complainant also concerned about mixing patient materials with promotional messaging and lack of approval code
Applicable Code year	2019
Complaint received	3 February 2021
Case completed	9 July 2021
No breach	Clause 9.1 (in relation to the allegation that combining patient materials and promotional messaging in the same email was inherently inappropriate)
Breach	Clauses 9.1, 14.1, 15.9
Sanctions	Undertaking received; additional sanctions not stated
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 employee) complained about an email sent to the salesforce titled “Toujeo news – Patient material & Digital campaign”.
The email announced availability of Toujeo SoloStar and DoubleStar printed patient booklets and how to order them.
Under “On another note”, the email described three HCP digital campaigns (including the BRIGHT digital campaign) and said reps were being made aware of BRIGHT in case HCPs reached out after seeing it.
The email stated it was for internal awareness only and not to be shared externally, and included screenshots showing promotional messaging from the BRIGHT campaign.
The complainant felt patient support updates should not be included in an email containing promotional messaging (risking interpretation that patient materials should be used to promote) and noted no approval code was visible.

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No breach of Clause 9.1 in relation to the allegation that it was inherently inappropriate to refer to patient materials and promotional messaging in the same email.
Breach of Clause 14.1 because the email was considered briefing/instructional material for representatives and should have been certified.
Breach of Clause 9.1 (high standards) in relation to the failure to certify/maintain high standards for such material (as acknowledged by Sanofi).
Breach of Clause 15.9 because the email functioned as representative briefing/instructions and was not certified as required.
No appeal.

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