UCB: Employee ‘liked’ LinkedIn post about Bimzelx, ruled promotion of a POM to the public (AUTH/3554/8/21)

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Key facts

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Case number	AUTH/3554/8/21
Company	UCB Pharma Ltd
Complainant	Anonymous, non-contactable complainant (member of the public/media)
Product	Bimzelx (bimekizumab)
Channel	LinkedIn (third-party post ‘liked’ by UCB employee)
Allegation	Promotion of a prescription-only medicine to the public on LinkedIn
Key timing noted by Panel	‘Like’ most probably on 24 August 2021; PLGB licence granted 25 August 2021; EU MA 20 August 2021; POM in Northern Ireland from 20 August 2021
Applicable Code year	2021
Breach clauses	2; 5.1; 26.1
Sanctions	Undertaking received; Additional sanctions: Advertisement
Complaint received	27 August 2021
Case completed	03 August 2022
Appeal	No appeal

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

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What happened

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An anonymous, non-contactable complainant (member of the public/media) complained about a LinkedIn post about Bimzelx (bimekizumab) made by a named organisation, which was shown as being ‘liked’ by a UCB Pharma Ltd employee.
The post congratulated UCB on “the first approval of bimekizumab” in the EU and included the claim: “BIMZELX is the first approved treatment for moderate to severe plaque psoriasis that is designed to selectively and directly inhibit both IL-17A and IL-17F.” It also included a link (content behind the link was not provided to the Panel).
UCB said the post was issued independently by the organisation without UCB’s instruction, permission or prior knowledge, and was not instigated/co-developed/commissioned/supported by UCB.
LinkedIn did not provide date/time stamps, so the exact date of the post and the ‘like’ could not be established. UCB inferred both most probably occurred on 24 August 2021.
The Panel considered, on the balance of probabilities, that the employee ‘liked’ the post on 24 August 2021 (one day before the PLGB licence for Great Britain was granted on 25 August 2021).
UCB submitted that Bimzelx became a prescription only medicine in Northern Ireland from 20 August 2021 (EU Commission authorisation), meaning it was a POM in part of the UK at the time of the ‘like’.
The Panel emphasised that on LinkedIn, “liking” can increase the likelihood content appears in connections’ feeds (“[name] likes this”) and can be visible via profile activity, potentially to members of the public depending on settings—so it can amount to proactive dissemination.
The Panel noted ambiguity in UCB’s then-current (June 2021) social media policy about how “liking” can disseminate content, and found the employee had not completed mandatory social media policy training (assigned 2 June 2021; due 2 July 2021; completed 3 December 2021 after the complaint).

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Outcome

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Breach of Clause 26.1 ruled (promotion of a prescription only medicine to the public via the employee’s ‘like’ and proactive dissemination on LinkedIn).
Breach of Clause 5.1 ruled (high standards not maintained).
Breach of Clause 2 ruled (conduct reduced confidence in the pharmaceutical industry, noting inadequate monitoring of completion of mandatory social media training and that Bimzelx was not licensed in Great Britain at the time of the activity).
No appeal (per case page).

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Key facts

What happened

Outcome

Clauses

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