AstraZeneca internal training role-plays with real HCPs: governance lapse found (AUTH/3578/11/21)

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Key facts

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Case	AUTH/3578/11/21
Complainant	Employee (could not be contacted using the details provided)
Company	AstraZeneca UK Limited
Issue	Allegations about training practices; role-plays with real HCPs including instances involving HCPs from employees’ own territories; concern about disguised promotion
Training format	Third-party delivered learning & development programme; Wave 1 negotiation skills module (“The Art of NHS Business to Business (B2B)”); simulated Zoom meetings with HCP consultants; monitored and recorded
Medicines referenced in fictitious case studies	Forxiga, Symbicort, Trixeo, Fasenra
Meetings with in-territory pairing	10 meetings (including 3 in the Devolved Nations)
Applicable Code year	2021
Breach	Clause 5.1
No breach	Clauses 2, 15.6, 19.1
Sanctions	Undertaking received; additional sanctions not stated
Complaint received	5 November 2021
Case completed	8 November 2022
Appeal	No appeal

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

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An AstraZeneca employee complained about internal “selling” training (Nov 2021) delivered with a third-party provider using real health professionals (HCPs) for simulated meetings/role-plays.
Participants were briefed that role-plays must not involve HCP/Payor customers from the employee’s own area/territory to avoid external perception of disguised promotion and to prevent using training to “sell”.
The complainant alleged multiple instances where role-plays were conducted with customers from representatives’/sales managers’ own territories, allegedly to access “hard-to-see” customers and sell to them.
AstraZeneca investigated and reported that Wave 1 included 31 groups and that there were 10 meetings (including 3 in the Devolved Nations) where an AstraZeneca employee was grouped with an HCP in their territory.
Training used fictitious but realistic health-system case studies; these referenced AstraZeneca medicines (Forxiga, Symbicort, Trixeo, Fasenra) and formulary status.
Each simulated meeting was monitored by an agency observer and recorded; AstraZeneca retrospectively reviewed recordings for the 10 “same territory” meetings and said it found no evidence of promotion.
HCPs were paid for their time at AstraZeneca fair market value (FMV) rates.

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Breach of Clause 5.1 (high standards) was ruled (acknowledged by AstraZeneca) because further steps could have been taken to ensure the compliance advice for the programme was followed.
No breach of Clause 15.6: the Panel considered, on balance, the module was a bona fide training event and the allegation of disguised promotion was not established.
No breach of Clause 19.1: no evidence that payments were not genuine consultancy fees.
No breach of Clause 2: the circumstances did not warrant the particular censure of Clause 2.
No appeal.

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