AUTH/3505/4/21: Complainant v Britannia — advisory boards and nursing service (No breach) | PMCPA Case

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Key facts

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Case number	AUTH/3505/4/21
Company	Britannia
Complainant	Anonymous ex-employee
Product(s)	Lecigon (levodopa/carbidopa/entacapone); APO-go (mentioned)
Main issues	Advisory boards (alleged marketing-led/disguised promotion; “EVOKE” branding; multiple meetings; KAM involvement); nursing service (alleged sales association and use of patient data for targeting)
Applicable Code year	2019
Clauses considered	Clause 2; Clause 9.1; Clause 12.1; Clause 19.2; Clause 23.1
Panel decision	No breach
Complaint received	19 April 2021
Case completed	21 September 2021
Appeal	No appeal
Additional sanctions	Not stated

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

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An anonymous ex-employee complained about Britannia’s arrangements for advisory boards linked to Lecigon (levodopa/carbidopa/entacapone), described as a new intestinal gel therapy for advanced Parkinson’s disease.
Allegations included that sales/marketing planned advisory boards with minimal medical input, branded them as “EVOKE”, held multiple meetings when one would do, and sought to use key account managers (KAMs) to facilitate and build advocacy.
The complainant also alleged Britannia’s nursing service was compromised by close association with sales, including a plan to use nursing service data for sales/targeting (as alleged to already be the case for APO-go).
Britannia said it investigated internally (led by compliance), provided interview summaries/materials, and stated two advisory boards were held in 2021 (payor-focused and KOL-focused) with medical/compliance oversight.
Britannia explained it used two separate software solutions: a nurse database (used by nurses/PV/medical) and a separate dashboard used by sales/customer service; the systems were not interlinked and users did not have access to both.
The Panel noted the complainant provided no evidence to support the allegations and that the PMCPA is not an investigatory body.

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No breach of the Code was ruled.
The Panel found the complainant had not established the allegations on the balance of probabilities regarding advisory board arrangements, alleged “EVOKE” branding/disguised promotion, KAM involvement, or inappropriate use/compromise of nursing service data.
The Panel expressed concern that the nursing service was under administration of the sales function (user approvals/budget holder), which Britannia acknowledged was not ideal and planned to explore reallocating to medical, but this did not amount to a breach on the evidence provided.

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