AUTH/3523/6/21: Novo Nordisk—LinkedIn post about early-phase pipeline (No breach)

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Key facts

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Case number	AUTH/3523/6/21
Company	Novo Nordisk
Complaint	Alleged advertising of pipeline products on LinkedIn to the general public
Material	LinkedIn post by third-party contractor; link to “R&D pipeline” page on novonordisk.com
Complainant	Concerned UK health professional
Complaint received	22 June 2021
Case completed	18 May 2022
Applicable Code year	2019
Panel view on scope	In scope: UK-based poster; post likely directed mainly to UK audience; likely available to public; links treated as part of the post
Clauses considered	2, 9.1, 26.1, 26.2
Decision	No breach of the Code
Appeal	No appeal

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

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A UK health professional complained about a LinkedIn post made (June 2021) by an individual contracted to work for Novo Nordisk A/S (Denmark) via a third-party talent acquisition agency.
The post stated: “Novo Nordisk has an extensive early phase clinical pipeline, of over 14 research projects in Phase 1. Contributing to the design, interpretation and reporting of development studies” and included hashtags (eg #Diabetes #Obesity #NASH #Haemophillia).
The post linked to Novo Nordisk’s website page titled “R&D pipeline” (Science & technology section), which allowed browsing pipeline products by therapy area and study phase (Phase 1/2/3/Filed) and, when clicked, showed class/intended use and links to clinical trials.
The complainant alleged the post appeared to promote products to the general public and that LinkedIn was not an appropriate venue for proactive dissemination of such material.
Novo Nordisk said the individual was not employed/contracted by the UK affiliate (Novo Nordisk Limited), the post was not instructed by the UK affiliate, was not certified, and was intended for recruitment engagement.
The Panel considered the individual resided in the UK and, on the balance of probabilities, the post was mainly directed to a UK audience; it also considered the audience likely included members of the public.

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No breach of the Code was ruled.
No breach of Clauses 26.1 and 26.2: the complainant did not establish that the post advertised a prescription only medicine (POM) to the public or encouraged the public to request a specific POM.
No breach of Clause 9.1: the complainant did not establish a failure to maintain high standards, noting the narrow nature of the allegation and burden of proof.
No breach of Clause 2: the circumstances did not warrant this “particular censure”.

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