Gilead (HIV.eu): HCP website content and PI links accessible to the public due to broken patient-site routing

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Key facts

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Case	AUTH/3603/1/22
Complainant	Anonymous (described as a concerned UK health professional)
Company	Gilead Sciences Europe Limited (GSEL)
Material / activity	Gilead Sciences Europe website HIV.eu (HCP site) and its routing to a patient/public site
Issue trigger	“Visit patient site” option not working; HCP site visible to public; missing obligatory information and PI link issues
Applicable Code year	2021
Complaint received	20 January 2022
Case completed	22 March 2023
Appeal	No appeal
Breach clauses	5.1, 12.1, 12.3, 12.10, 26.1, 26.2
No breach clauses	2
Sanctions	Undertaking received; additional sanctions not stated

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

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An anonymous UK health professional complained about Gilead Sciences Europe’s website HIV.eu, intended for healthcare professionals.
The landing pop-up offered “CONTINUE TO SITE” (HCP) or “VISIT PATIENT SITE” (public). The complainant said the patient option failed, leaving the HCP site visible for long enough to browse before an error page (“This site can’t be reached”).
A top navigation “Prescribing Information” drop-down listed multiple Gilead HIV medicines; the complainant alleged missing generic names, missing black triangle for Biktarvy, and that links did not provide prescribing information (and one link did not work reliably).
Gilead said the site used OneKey validation to restrict promotional content, and suspended access to HIV.eu while investigating.
The Panel reviewed what could be seen before OneKey login and considered that some pre-login content (including text shown when clicking a padlocked resource) was promotional and referenced Biktarvy/B/F/TAF in a way that could be seen by the public during the routing failure.

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Breach of Clause 26.1: on the balance of probabilities, promotional information aimed at health professionals was available to members of the public.
Breach of Clause 26.2: statements seen could encourage members of the public to ask their health professional to prescribe a specific prescription only medicine.
Breach of Clause 12.1: prescribing information was incomplete (cost information missing) and a link (Atripla) did not work, so obligatory information requirements were not met.
Breach of Clause 12.3: non-proprietary names were not immediately adjacent to the first/most prominent display of brand names in the prescribing information drop-down list.
Breach of Clause 12.10: Biktarvy was missing the inverted black triangle on the website at first mention.
Breach of Clause 5.1: failure to maintain high standards.
No breach of Clause 2: Panel considered the breach rulings adequately covered the matter and an additional Clause 2 finding would be disproportionate.

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Breach of Clause 5.1 Failing to maintain high standards
Breach of Clause 12.1 Failing to include up-to-date prescribing information
Breach of Clause 12.3 Failing to include the non-proprietary name
Breach of Clause 12.10 Failing to include the black triangle
Breach of Clause 26.1 Advertising prescription only medicines to the public
Breach of Clause 26.2 Encouraging members of the public to ask for 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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