Daiichi Sankyo breached Code over uncertified mobile ‘final form’ differences on Lixiana HCP and patient websites (AUTH/3615/3/22)

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Key facts

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Case	AUTH/3615/3/22
Company	Daiichi Sankyo
Product	Lixiana (edoxaban)
Issue	Alleged failure to certify mobile versions where desktop and mobile “final form” differed
Materials	HCP promotional website (lixiana-hcp.co.uk) and patient website (myanticoagulant.co.uk)
Key differences cited	HCP site: cropped image and claim colour differed (pink vs white). Patient site: different patient illustrations on mobile vs desktop.
Applicable Code year	2021
Complaint received	10 March 2022
Case completed	2 December 2022
Appeal	No appeal
Breach clauses	8.1, 8.3
No breach clauses	2, 5.1
Sanctions	Undertaking received; Additional sanctions: Not stated

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

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An anonymous, contactable complainant alleged Daiichi Sankyo had not properly certified mobile versions of Lixiana (edoxaban) webpages.
On the HCP promotional site (lixiana-hcp.co.uk), the desktop and mobile views differed across four pages (including the homepage): the patient-heads image appeared cropped on mobile and the claim “Your choice for ageing patients with NVAF” appeared in pink on desktop but white on mobile.
On the patient site (myanticoagulant.co.uk), desktop and mobile views used different patient illustrations (female on the NVAF page; male on the VTE page), meaning the content presented differed by platform.
Daiichi Sankyo argued the Code did not require separate job bags for mobile versions and said the signatory checked desktop and mobile as part of the final form check under the same job bag number.
The Panel considered PMCPA guidance: separate certification is not required only if companies are confident the final form will be identical across platforms.

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Breach of Clause 8.1 (HCP webpages): mobile and desktop were not identical (colour difference), so each final form should have been certified separately.
No breach of Clauses 5.1 and 2 (HCP webpages).
Breach of Clause 8.3 (patient webpages): different images were used on mobile vs desktop, so each final form should have been certified separately.
No breach of Clauses 5.1 and 2 (patient webpages).
No appeal.

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