Roche Resources website: mobile view hid prescribing information and AE reporting statements (AUTH/3552/8/21)

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Key facts

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Case	AUTH/3552/8/21
Complainant	Anonymous health professional
Company	Roche
Material/channel	Roche Resources website (mobile vs desktop); homepage and medicines page; Polivy webpage also considered
Core issue	PI link and AE reporting statement not sufficiently prominent on some mobile devices; insufficient evidence of device review prior to certification
Applicable Code year	2021
Complaint received	5 August 2021
Case completed	27 May 2022
Appeal	No appeal
Breach clauses	Clause 5.2; Clause 8.1; Clause 12.6; Clause 12.9
No breach clauses	Clause 2; Clause 5.1; Clause 5.2; Clause 6.1; Clause 6.2; Clause 14.4
Sanctions	Undertaking received; Additional sanctions: Not stated

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

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An anonymous health professional complained about the mobile version of Roche’s HCP-facing “Roche Resources” website (rocheresources.co.uk), saying it differed from desktop and appeared not to have been properly certified for mobile use.
On some smartphones, the prescribing information (PI) link moved into a “hamburger” menu rather than being immediately visible.
The adverse event (AE) reporting statement was present but placed in the footer in smaller text and was not considered sufficiently prominent; on some devices an AE reporting link also moved into the hamburger menu.
The complainant also raised concerns about a Polivy webpage (claims “Recommended by NICE and SMC”, headline “Time to appreciate life”, and imagery implying contraception warnings should be highlighted). These allegations were not upheld.
Roche said the site was designed primarily for desktop/laptop and certified on that basis, with additional checks on devices such as an iPad; Roche took the site offline to investigate and implement corrective actions.

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Breach of Clause 12.6 (PI statement not clear/prominent on mobile where it sat in a hamburger menu) – ruled for the homepage and medicines page.
Breach of Clause 12.9 (AE reporting statement not sufficiently prominent; footer text too small) – ruled for the homepage and medicines page.
Breach of Clause 8.1 (certification of dynamic content: insufficient evidence of review across commonly used devices; if desktop-only design, this should have been stated) – ruled.
Breach of Clause 5.1 (high standards not maintained) – ruled in relation to the inadequate device review/certification approach.
No breach of Clause 2 (Panel did not consider the circumstances warranted this “particular censure”).
No breach findings for the Polivy webpage allegations under Clauses 6.1, 6.2, 14.4, and (for the narrow image allegation) Clauses 5.1 and 5.2.

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