Alnylam: Agency LinkedIn post promoted Oxlumo to the public (breach of Clause 26.1; no breach of Clauses 2 and 9.1)

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Key facts

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Case	AUTH/3473/2/21
Company	Alnylam
Product	Oxlumo (lumasiran)
Channel	LinkedIn (agency post)
Main issue	Promotion of a prescription only medicine to the public via an agency/sub-contractor LinkedIn post
Complaint received	10 February 2021
Case completed	12 August 2021
Applicable Code year	2019
Breach clauses	Clause 26.1
No breach clauses	Clause 2; Clause 9.1
Sanctions	Undertaking received; Additional sanctions: Not stated
Appeal	No appeal

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

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A contactable complainant alleged a LinkedIn post by an agency promoted Oxlumo (lumasiran) to the public, naming the product and describing it as the “first and only FDA-approved prescription medicine” for PH1.
Alnylam Switzerland GmbH had commissioned an agency to help prepare an Oxlumo digital sales aid for the CEMEA region; it had not been reviewed or used in the UK.
Contrary to the agreement, the commissioned agency sub-contracted another agency without Alnylam’s prior consent.
The LinkedIn post was published on the sub-contracted agency’s LinkedIn page and shared by its owner, showcasing work done for Alnylam and including previews that appeared to show: (1) the “first and only FDA-approved…” statement and (2) the Oxlumo logo with non-proprietary name and formulation (“for injection 94.5mg/0.5mL”).
Alnylam said it first became aware of the post when notified by the PMCPA; it contacted the sub-contracted agency the same day and the post was removed within three hours of Alnylam becoming aware.
The sub-contracted agency acknowledged the post was published without the consent of Alnylam or the originally contracted agency.

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Breach ruled: Clause 26.1 (advertising a prescription only medicine to the public).
No breach ruled: Clauses 2 and 9.1.
The Panel accepted that Alnylam had been “very badly let down” by third parties and that the contract terms (as described) should have prevented the post.

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