GSK corporate website: investor page wording seen as public promotion of POMs (AUTH/3573/10/21)

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Key facts

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Case	AUTH/3573/10/21
Complainant	Anonymous, contactable complainant (health professional)
Company	GlaxoSmithKline UK Limited
Material	GSK Global UK corporate website: “Our Pipeline” page and “About GSK” investor page
Key products named	Trelegy; Nucala; Triumeq/Tivicay
Main issue	Investor page wording and context implied promotional claims for POMs to the public
Applicable Code year	2021
Complaint received	27 October 2021
Case completed	7 September 2022
Appeal	No appeal
Breach clauses	Clause 5.1; Clause 26.1; Clause 26.2
No breach clauses (as ruled)	Clause 2; Clause 8.1; Clause 9.1; Clause 11.1; Clause 12.1; Clause 12.9 (and no breach findings for other alleged points as described in the ruling)
Sanctions	Undertaking received; Additional sanctions: Not stated

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

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An anonymous, contactable complainant (health professional) alleged GSK’s Global UK corporate website promoted its product pipeline to UK health professionals.
The complainant also alleged an investor webpage (accessible to the public) promoted prescription-only medicines (POMs) by naming products and linking them with indications, without required information.
Pipeline page (“Our Pipeline”): contained a low-key table listing compound/generic name, indication, phase and mode of action/vaccine type, within a clearly labelled “Research and development” section.
Investor page (“About GSK” within Investors): included statements such as “differentiated, high-quality and needed healthcare products” and described “innovative and established medicines”, followed by “Key products” listing Trelegy – Asthma/COPD, Nucala – Severe Asthma, and Triumeq/Tivicay – HIV.
The Panel considered that, in context, the investor page could imply the three named medicines were “established”, “high-quality” and “innovative” treatments needed for the listed indications.

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Pipeline page: No breach (not established as directed to health professionals; did not constitute promotion of unlicensed medicines; certification allegation not made out).
Investor page: Breach for promotion of POMs to the public and failure to meet requirements for financial information being non-promotional.
High standards: breach found in relation to the investor page.
Clause 2: no breach (Panel said circumstances did not warrant the particular censure of Clause 2).
Training (Clause 9.1): no breach (allegation not made out).
Promotion to health professionals / PI / AE statement (Clauses 12.1, 12.9): no breach (page not directed to or limited to HCPs; allegations not relevant on the facts).

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