Novo Nordisk: LinkedIn post by third-party contractor deemed promotional and uncertified (AUTH/3604/1/22)

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Key facts

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Case	AUTH/3604/1/22
Company	Novo Nordisk
Issue	Concerns about promoting to the public on LinkedIn; certification of a promotional post
Channel	LinkedIn (personal/work-related account) with link to FiercePharma article
Who posted	UK-based individual contracted to work for Novo Nordisk A/S via a third-party company
Timing of post	Approximately June 2021
Complaint received	20 January 2022
Case completed	20 February 2023
Applicable Code	2021
Breach clauses	Clause 5.1
No breach clauses	Clauses 2, 5.1, 8.3, 26.1
Sanctions	Undertaking received; Additional sanctions: Not stated
Appeal	No appeal

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

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A UK-based individual contracted to work for Novo Nordisk A/S (via a third-party talent acquisition company) posted on LinkedIn (approx. June 2021).
The post referenced a planned phase 3a trial of “oral semaglutide 50mg” and linked to a FiercePharma article about semaglutide/Wegovy, including efficacy/weight-loss statements and market-disruption language.
The individual’s LinkedIn headline described them as a sourcing specialist “at Novo Nordisk via” the agency; they had 5,000+ followers and 500+ connections.
Novo Nordisk said it did not instruct the post, had no knowledge of it, and the post was not certified.
The Panel considered the post (and the linked article) to be part of the same communication and, on the balance of probabilities, directed to a UK audience and likely accessible to members of the public.

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Breach: Clause 5.1 (Failure to maintain high standards) due to failure to certify a promotional LinkedIn post in line with Clause 8.1.
No breach: Clause 8.3 (Requirement to certify non-promotional material) because the post was promotional, so 8.3 was not relevant.
No breach: Clause 26.1 (Requirement to not advertise prescription only medicines to the public) because oral semaglutide 50mg did not appear to be marketed/classified as a prescription only medicine at the time.
No breach: Clause 2 (Requirement that activities or material must not bring discredit upon, or reduce confidence in, the pharmaceutical industry).
No breach: Clause 5.1 (Requirement to maintain high standards) was also recorded as no breach in relation to the narrow allegation about promoting a POM to the public; however, a breach of Clause 5.1 was ruled for the certification failure.

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Breach of Clause 5.1 Failure to maintain high standards
No Breach of Clause 8.3 Requirement to certify non-promotional material
No Breach of Clause 26.1 Requirement to not advertise prescription only medicines to the public
No Breach of Clause 5.1 Requirement to maintain high standards
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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