LEO Pharma: late and incomplete disclosure of patient organisation support (AUTH/3498/3/21)

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Key facts

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Case	AUTH/3498/3/21
Parties	Anonymous, contactable ex-employee v LEO
Topic	Information on payments to patient organisations (website list / Disclosure UK)
Applicable Code year	2019
Complaint received	29 March 2021
Case completed	18 November 2021
Key organisations mentioned	National Eczema Society; Thrombosis UK; Changing Faces
Key amounts mentioned	NES: £1,000 (2018, disclosed on Disclosure UK); Trekfest: £5,217.43 raised and matched by LEO to total £10,434.86 (2019); Thrombosis UK: £2,400 (Apr 2019), £325.60 (Jul 2019), £800 (Oct 2019)
Breach clauses (final)	Clause 27.7; Clause 9.1
No breach clauses (final)	Clause 2
Sanctions	Undertaking received; Additional sanctions: Not stated
Appeal	Respondent appeal; successful regarding multiple Clause 27.7 breaches (treated as one) and Clause 2 (overturned)

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

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An anonymous, contactable ex-employee complained about LEO Pharma UK/IE’s public disclosures of support to patient organisations (company website list and Disclosure UK).
The complaint focused on a website document: “List of patient organisations which Leo Pharma UK/IE has provided support in the years 2018 and 2019” (January 2021), alleging errors/omissions.
2018: The complainant said a £1,000 transfer of value to the National Eczema Society (NES) appeared on Disclosure UK but not on LEO’s patient organisation list, and argued NES was a patient organisation so should have been listed there.
2019: A LEO UK/IE tweet (17 September 2019) described a Trekfest fundraising cheque of £5,217.43 raised by employees, matched by LEO to total £10,434.86 for NES; the complainant alleged LEO’s donation element was not disclosed on the patient organisation list for 2019.
2019: The complainant noted three payments to Thrombosis UK (April 2019 £2,400; July 2019 £325.60; October 2019 £800) appeared only in the January 2021 version of the list (not the December 2020 version), implying disclosure was outside the required timeframe.
The complainant also argued that descriptions of support were unclear for some entries (including Thrombosis UK items and a 2018 “Changing Faces” entry), but provided limited specific evidence beyond examples.

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Breach (2019 Code): Clause 27.7 – LEO’s 2019 patient organisation list omitted LEO’s Trekfest-related donation to the National Eczema Society.
Breach (2019 Code): Clause 27.7 – late disclosure of 2019 payments to Thrombosis UK (ultimately treated as one breach on appeal).
Breach (2019 Code): Clause 9.1 – failure to maintain high standards, given repeated errors/omissions in the disclosure list even after earlier issues had been raised (AUTH/3418/11/20).
No breach (appeal outcome): Clause 2 – the Panel had ruled a breach, but the Appeal Board overturned it.
No breach (2016 Code): No breach was found regarding the 2018 £1,000 NES disclosure being on Disclosure UK rather than the patient organisation list; and no breach was found regarding the sufficiency of description for the specific examples assessed under the 2016 Code.

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