Almirall: UK employee ‘liked’ global LinkedIn post, triggering UK Code breaches for public promotion and lack of certification/PI (AUTH/3479/2/21)

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Key facts

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Case	AUTH/3479/2/21
Company	Almirall
Complaint	Alleged promotion of a medicine on LinkedIn (global post ‘liked’ by senior UK employee)
Medicine	Tildrakizumab (Ilumetri)
Channel	LinkedIn
Key issue	‘Like’ treated as proactive dissemination; POM named with efficacy/safety claims; likely public availability; no certification; no prescribing information
Complaint received	25 February 2021
Case completed	11 October 2021
Applicable Code year	2019
Breach clauses	4.1, 9.1, 14.1, 26.1, 26.2
No breach clauses	2, 14.3
Sanctions	Undertaking received; Additional sanctions: Not stated
Appeal	No appeal

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

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A health professional complained about a LinkedIn post that appeared in their feed, originally posted by Almirall’s Spanish head office and ‘liked’ by a senior UK employee.
The post stated “Good news for psoriasis patients all over Europe” and claimed long-term efficacy and safety over 5 years in moderate to severe psoriasis; a quote beneath named “tildrakizumab” (marketed as Ilumetri).
The complainant queried whether the post had been checked/approved and noted the absence of safety/prescribing information; they also questioned why multiple Almirall individuals were ‘liking’ posts.
Almirall said the UK employee’s ‘like’ was human error, contrary to its UK social media policy, and accepted that the ‘like’ brought the content into scope of the UK Code.
Almirall actions after notification (2 March 2021): the employee removed references the same day; the global post was deleted by the next day; refresher training on the UK Social Media Policy was delivered to the UK team on 3 March.
The Panel considered that ‘liking’ can amount to proactive dissemination to a new audience and that employees should assume such activity may be visible to both health professionals and members of the public.

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Breach of Clause 26.1 (promotion of a prescription only medicine to the public).
Breach of Clause 26.2 (information likely to encourage members of the public to ask their health professional for tildrakizumab).
Breach of Clause 14.1 (material not certified; the employee’s ‘like’ effectively created/disseminated a new piece of promotional material).
Breach of Clause 4.1 (promotion to health professionals without prescribing information).
Breach of Clause 9.1 (high standards not maintained).
No breach of Clause 14.3 (Panel did not consider the post to be educational material for the public; clause did not apply).
No breach of Clause 2 (Panel considered an additional Clause 2 breach would be disproportionate in the circumstances).

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