GSK employee’s personal LinkedIn post about “shingles prevention” and Shingrix role: no breach (AUTH/3617/3/22)

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Key facts

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Case number	AUTH/3617/3/22
Company	GlaxoSmithKline
Product	Shingrix (herpes zoster vaccine)
Channel	LinkedIn (personal post and personal profile “Experience” section)
Allegation	Promotion of a prescription only medicine to the public; lack of prescribing information; concerns about training and discredit to industry
Applicable Code	2021
Clauses considered	2, 9.1, 12.1, 26.1
Outcome	No breach of Clauses 2, 9.1, 12.1, 26.1
Complaint received	09 March 2022
Case completed	10 March 2023
Appeal	No appeal
Sanctions	None

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

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An anonymous, non-contactable complainant (a self-described health professional) alleged Shingrix (herpes zoster vaccine) was promoted on LinkedIn.
The complaint related to: (1) a personal LinkedIn post announcing a new role at GSK with hashtags including #ShinglesPrevention; and (2) the individual’s LinkedIn “Experience” section which referenced “[role] – Shingrix” and included responsibilities related to consumer shingles disease awareness campaigns.
The complainant alleged breaches of Clauses 2 and 9.1, and also alleged there was no prescribing information and that there was a link to the GSK vaccines site.
The Authority asked GSK to consider Clauses 2 and 9.1 (as cited) and additionally Clauses 12.1 and 26.1 (2021 Code).
GSK said the post was made just before the individual started employment; the content remained live after employment began. GSK said the post did not name a product and was disease-awareness oriented, noting there were two shingles vaccines available in the UK national programme at the time.
GSK said the “Experience” section functioned like a CV and required active searching/clicking/scrolling to view; the linked GSK vaccines webpage was general and did not name products or make claims.
After becoming aware of the complaint, GSK said the employee removed the post and adapted the “Experience” section (despite denying breaches).

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No breach of Clause 26.1 (LinkedIn post): complainant did not establish that the post promoted Shingrix to the public; at the time GSK was not the only company with a medicine related to “shingles prevention”.
No breach of Clause 26.1 (Experience section): the Panel considered it required active navigation and was distinct from proactively disseminated “Activity” content; therefore not advertising a POM to the public.
No breach of Clause 12.1: the Panel did not consider the Experience section constituted promotion to health professionals, so prescribing information was not required.
No breach of Clause 9.1: complainant did not establish lack of training; GSK described onboarding and annual social media/Code-related training, completed by the employee shortly after starting.
No breach of Clause 2: followed from the no-breach findings.
No appeal.

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Clause 2 Requirement that activities or material must not bring discredit upon, or reduce confidence in, the pharmaceutical industry
Clause 9.1 Requirement that all relevant personnel concerned with the preparation or approval of material or activities covered by the Code must be fully conversant with the Code and the relevant laws and regulations
Clause 12.1 Requirement to include prescribing information
Clause 26.1 Requirement not to advertise prescription only medicines to the public

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