Croma Pharma: Monaco Letybo launch symposium ruled to create an impression of excessive hospitality

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Key facts

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Case numbers	AUTH/3644/5/22 and AUTH/3694/10/22
Company	Croma Pharma
Product	Letybo (botulinum toxin type A)
Issue	Excessive hospitality / inappropriate venue and impression at a launch symposium
Event location	Monaco
Event timing	April 2022
Complaint received	10 May 2022
Case completed	8 June 2023
Applicable Code year	2021
Complainant	Anonymous, non-contactable member of the public; identical complaint later referred by MHRA
UK delegate involvement	11 UK health professionals attended; 2 were speakers; UK staff present to welcome/accompany UK delegates
Panel decision (breaches)	Clause 2; Clause 5.1; Clause 10.1
Appeal	No appeal
Sanctions	Undertaking received; Advertisement

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

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An anonymous member of the public complained about a Croma Pharma Letybo (botulinum toxin type A) launch symposium held in Monaco in April 2022 (AUTH/3644/5/22); an identical complaint was later referred by the MHRA (AUTH/3694/10/22).
The complainant alleged the event involved luxury hospitality disproportionate to the scientific content, citing a five-star “Leading Hotels of the World” venue and hotel signage stating “Cocktails, meeting, and dinner”.
Social media posts were referenced by the complainant as evidence of the event’s “feel” (eg “Doctor’s dinner start with a little bit of science” and hashtag “#fashionevent”).
Croma said the event was organised/hosted by Croma Pharma Austria; the UK affiliate did not sponsor UK delegates to attend the congress and had no involvement in logistics.
Croma stated UK HCPs who were already attending the congress were verbally invited to the scientific session and dinner; 11 UK health professionals attended, including 2 UK speakers; UK affiliate staff attended to welcome and accompany UK delegates.
Croma said there were 90 minutes of scientific content plus Q&A, followed by dinner with wine/beer/soft drinks; it stated no cocktails were served and costs were within the £75 + VAT + service charge guideline (invoice provided, partially redacted).

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The Panel decided the arrangements for the symposium (as they related to UK delegates) fell within the scope of the UK Code, given the verbal invitation of UK HCPs and the formal role of UK staff accompanying them.
The Panel ruled that the overall impression created meant hospitality (including the venue) did not appear secondary to the meeting’s purpose; the five-star Monaco venue was considered inappropriate and could have attracted delegates for reasons other than the scientific programme.
The poor impression was compounded by the signage referencing “Cocktails”.
Breaches were ruled of Clauses 10.1, 5.1 and, on balance, Clause 2.
No appeal.

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