Sobi: pressure to inflate CRM activity, unclear call vs contact briefings, contract timing failures and recertification lapse (AUTH/3535/7/21)

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Key facts

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Case	AUTH/3535/7/21
Parties	Employee v SOBI
Complaint received	8 July 2021
Case completed	7 July 2022
Applicable Code year	2019
Therapy area / products mentioned	Haemophilia; Elocta (efmoroctocog alfa), Alprolix (eftrenonacog alfa); Doptelet mentioned in relation to internal training material
Main issues upheld	Encouraging inaccurate CRM logging (emails as calls); unclear activity briefings re call vs contact rates; post-certification slide edit without re-certification; HCP prep work before contracts
Clause 2 outcome	No breach (upheld on appeal)
Sanctions	Undertaking received; Additional sanctions: Not stated

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

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An employee complained about Sobi UK haematology field force activities, meetings/marketing materials, and representative training for haemophilia brands Elocta and Alprolix.
Management focus on “activity” increased; briefings and emails set activity expectations without clearly distinguishing call rates vs contact rates (and without clearly referencing Code requirements in those briefings).
Audio/transcripts showed a senior leader encouraged staff to record email exchanges as telephone calls because emails did not “count” towards activity KPIs.
Two health professional (HCP) engagements: preparatory work was done before written contracts were in place (including work done before a cancelled webinar, and preparation prior to a rehearsal for another webinar).
A webinar slide deck was amended on the day (changing “Mrs” to “Ms”) after certification, without re-certification.
Other allegations (eg, overcalling beyond unsolicited call limits; disguised market research; patient identifiers; missing black triangle on internal training material; lack of training) were largely not upheld on the evidence provided.
The complainant appealed the finding of no breach of Clause 2; the Appeal Board upheld no breach of Clause 2.

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Breach found: Clause 9.1, Clause 14.1, Clause 15.4, Clause 15.9, Clause 23.1.
No breach found: Clause 2, Clause 4.10, Clause 12.1, Clause 15.1 (and no breach of Clause 15.4 regarding exceeding the limit on unsolicited calls, based on evidence).
Appeal: complainant’s appeal on Clause 2 was unsuccessful; no breach of Clause 2 was upheld.

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