AstraZeneca employee’s LinkedIn ‘like’ and comment held to be POM advertising to the public (AUTH/3599/1/22)

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Key facts

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Case	AUTH/3599/1/22
Complainant	Hospital consultant (endocrine medicine)
Company	AstraZeneca
Channel	LinkedIn (employee post; employee ‘like’ and comment on third-party post)
Medicines mentioned	Forxiga (dapagliflozin); lisinopril and other BP drugs referenced in the complaint
Main issue upheld	Employee ‘liked’ and commented on a third-party dapagliflozin post, potentially disseminating POM promotion to the public
Applicable Code	2021
Complaint received	16 January 2022
Case completed	11 April 2023
Appeal	No appeal
Breaches	Clause 5.1; Clause 26.1; Clause 26.2
No breach findings	Clause 2; Clause 5.5; Clause 26.1 (in relation to the BP post allegation); Clause 26.2 (in relation to the BP post allegation)
Sanctions	Undertaking received; Additional sanctions not stated

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

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A hospital consultant complained about two LinkedIn items involving an AstraZeneca employee: (1) the employee’s own post about a blood pressure (BP) study; and (2) the employee ‘liking’ and commenting (“Congratulations”) on another researcher’s post about dapagliflozin (Forxiga) in HFpEF.
The complainant alleged the posts promoted prescription-only medicines (including Forxiga/dapagliflozin and lisinopril/hydrochlorothiazide) to the public and that conflicts of interest/affiliation were not clearly declared.
AstraZeneca’s internal investigation found the employee had posted about a BP paper co-authored before joining AstraZeneca; AstraZeneca said it had no involvement in that study and that conflicts were declared in the manuscript acknowledgements.
AstraZeneca accepted the employee’s ‘like’ and comment on the dapagliflozin post breached its internal social media policy; it took action to remove the ‘like’ and comment and reminded the employee of the policy.
The Panel considered that liking/commenting could proactively disseminate the third-party post to members of the public within and outside the employee’s LinkedIn network.

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Breach for the employee’s ‘like’ and comment on a third-party LinkedIn post about dapagliflozin: advertising a prescription-only medicine to the public and potentially encouraging the public to ask their health professional to prescribe it.
No breach for the employee’s own BP-study LinkedIn post on the narrow allegation that it promoted named AstraZeneca medicines to the public; the Panel did not find it unfactual/unbalanced or raising unfounded hopes as alleged.
No breach regarding alleged lack of clear conflict of interest/affiliation declaration in the BP paper (the Panel considered disclosures in the acknowledgements were clear on the information before it).
No breach of Clause 2; the Panel considered the breach rulings adequately covered the matter and an additional Clause 2 breach would be disproportionate in the circumstances.

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Breach of Clause 5.1 Failing to maintain high standards
Breach of Clause 26.1 Advertising a prescription only medicine to the public
Breach of Clause 26.2 Encouraging members of the public to ask their health professional for a specific prescription only medicine
No Breach of Clause 5.5 Requirement to clearly indicate the role of the pharmaceutical company
No Breach of Clause 26.1 Requirement to not advertise prescription only medicines to the public.
No Breach of Clause 26.2 Requirement that information about prescription only medicines which is made available to the public must be factual, balanced, must not raise unfounded hopes of successful treatment or encourage the public to ask their health professional to prescribe a specific prescription only medicine.
No Breach of Clause 2 Requirement that activities or material must not bring discredit upon, or reduce confidence in, the pharmaceutical industry.

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