AUTH/3608/2/22: Complainant v AstraZeneca — LinkedIn World Cancer Day post alleged public promotion (No breach) | PMCPA Case

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Key facts

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Case number	AUTH/3608/2/22
Company	AstraZeneca
Allegation	Alleged promotion to the public on LinkedIn (including alleged promotion of oncology portfolio/pipeline and pre-authorisation promotion)
Channel	LinkedIn (personal account of a named senior employee; link to AstraZeneca Global LinkedIn account)
Applicable Code year	2021
Clauses considered	2, 5.1, 11.1, 26.1
Decision	No breach
Complaint received	08 February 2022
Case completed	21 November 2022
Appeal	No appeal
Notes from Panel	Post did not name medicines/indications; no direct link to pipeline; accessing pipeline required multiple steps and active searching; Clause 11.1 applies to HCP/relevant decision makers; public pre-authorisation concerns would be under Clause 3.1 (not raised) and were considered under Clause 5.1

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

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A contactable complainant (self-described medical oncologist) alleged AstraZeneca promoted its current and future oncology pipeline to the public via LinkedIn.
The LinkedIn post was made by a named senior AstraZeneca UK employee on their personal account, referencing World Cancer Day and AstraZeneca “helping lead a revolution in oncology”.
The post thanked the wider cancer community and said AstraZeneca was proud to develop innovative medicines and initiatives to improve outcomes and “move towards a world without cancer”.
The complainant alleged the post shared a “live link” to AstraZeneca’s oncology portfolio and pipeline and that many AstraZeneca staff “liked” the post.
The complainant alleged this could raise unfounded hopes and lead patients to request access to phase 1–3 molecules whose safety/efficacy was not proven.
AstraZeneca said the post was non-promotional, named no medicines/indications, and linked only to AstraZeneca’s global LinkedIn account; reaching pipeline information required multiple steps (at least three clicks) and active searching.
AstraZeneca stated the post had been reviewed and certified by a signatory under its social media SOP and that employees were trained on the SOP.

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No breach of the Code was found.
The Panel did not consider the post (or employees “liking” it) promoted AstraZeneca’s oncology portfolio or pipeline products to the public prior to marketing authorisation.
The Panel did not consider the complainant established that the post raised unfounded hopes for patients or trivialised the work of a named London hospital.
The Panel ruled no breach of Clause 11.1, noting it applies to promotion to health professionals/other relevant decision makers; public pre-authorisation concerns would fall under Clause 3.1 (not raised) and were considered under Clause 5.1.
Consequently, the Panel also ruled no breach of Clause 2.

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