Daiichi-Sankyo: Lixiana symposium recording on Vimeo viewable by the public (AUTH/3507/5/21 & AUTH/3513/5/21)

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Key facts

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Case number(s)	AUTH/3507/5/21; AUTH/3513/5/21
Company	Daiichi-Sankyo
Product	Lixiana (edoxaban)
Activity type	Sponsored promotional symposium; recording uploaded to Vimeo
Material / job code	EDX/21/0047 (March 2021)
Main issue	Promotional video accessible to the public due to incorrect Vimeo privacy settings
Applicable Code year	2019
Complaint received	03 May 2021
Case completed	06 December 2021
Appeal	No appeal
Breach clauses	26.1; 26.2
No breach clauses	2; 7.2; 7.4; 9.1; 11.1; 29
Sanctions	Undertaking received; Additional sanctions: Not stated

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

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An anonymous complainant raised two related complaints about promotion of Lixiana (edoxaban) linked to a sponsored symposium: “Anticoagulation in stroke prevention: Optimising clinical and medicines management” (Job code EDX/21/0047; March 2021) run as part of the Celtic Conference (virtual meeting on 11 March 2021).
The complainant alleged the session was promoted to inappropriate audiences (health board members, education providers, practice managers, and pharmacy assistants) and that content was not tailored to them.
The complainant alleged a headline claim “Anticoagulation with DOACs is cost effective” was misleading because (they said) no cost-effectiveness analysis had been done for Lixiana.
The complainant alleged the symposium recording was placed on Vimeo (an open access platform), meaning a prescription only medicine (Lixiana) was promoted to the public.
The complainant also alleged this Vimeo availability breached an undertaking given by Daiichi-Sankyo in a previous case (AUTH/3107/10/18) about not promoting POMs to the public.
Daiichi-Sankyo said the meeting organisers (not an agency acting on its behalf) uploaded the recording to Vimeo to share with Daiichi-Sankyo only, but the video had incorrect privacy settings due to organiser error; Daiichi-Sankyo requested removal once aware.

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Breach: The Vimeo-hosted promotional video was viewable by members of the public due to incorrect privacy settings; this amounted to advertising a prescription only medicine to the public and could encourage someone to ask their health professional to prescribe Lixiana.
No breach: Audience targeting/tailoring allegations were not established on the evidence (complainant did not discharge burden of proof).
No breach: The “cost effective” allegation (framed narrowly as “no cost-effectiveness analysis had been done for Lixiana”) was not established on the evidence.
No breach: No breach of Clause 2 (high standards / discredit) in the circumstances.
No breach: No breach of Clause 29 (undertaking) because the circumstances were sufficiently different from the earlier case, particularly due to the role/error of the meeting organisers.

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