AUTH/3499/4/21: Daiichi-Sankyo website page promoted Efient and Lixiana to the public and breached a prior undertaking

📅 2021 | 🖉 Dr Anzal Qurbain
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Key facts

CaseAUTH/3499/4/21
CompanyDaiichi-Sankyo
Complaint received02 April 2021
Case completed06 December 2021
Applicable Code year2019
MedicinesEfient (prasugrel); Lixiana (edoxaban)
ChannelCorporate website page (externally accessible via site search)
Main issuesPromotion of POMs to the public; lack of audience restriction/identification; lack of prescribing information; lack of certification; breach of prior undertaking
Breach clauses4.1, 9.1, 14.1, 26.1, 26.2, 28.1, 28.3, 29
No breach clauses2, 26.3
AppealNo appeal
SanctionsUndertaking received; Additional sanctions: Not stated

Download the full case report (PDF)


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

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What happened

  • An anonymous complainant alleged Daiichi-Sankyo promoted prescription-only medicines (Efient/prasugrel and Lixiana/edoxaban) to the public via a corporate website page.
  • The page included brand and generic names, mechanism of action and indications, and was freely accessible (at least via the website search function).
  • The complainant also alleged this repeated an earlier issue and breached an undertaking given in Case AUTH/3107/10/18.
  • Daiichi-Sankyo said the antithrombotic section had been disabled in March 2019, but one subpage was mistakenly enabled due to human and technical error and became externally accessible.
  • The page was not accessible via normal navigation/footers, but could be found via certain search terms; Daiichi-Sankyo deleted the page after the complaint and stated product-name searches would route to approved pages.
  • Daiichi-Sankyo stated the page had not been reviewed by a medical signatory and was never intended for external publication.
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Outcome

  • Breaches were ruled for promotion of POMs to the public and failure to restrict access/identify intended audience on the website.
  • Breaches were ruled for lack of prescribing information and lack of certification/signatory review.
  • A breach was ruled for failure to comply with a previous undertaking (AUTH/3107/10/18).
  • No breach was ruled for Clause 26.3 (patient side-effect reporting statement) because the Panel did not consider it established that the page was intended for patients taking the medicines.
  • No breach was ruled for Clause 2 (the Panel did not consider the circumstances warranted this particular censure).
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