Teva breached Code over Ajovy HCP registration website: PI link not prominent and black triangle missing at first mention (AUTH/3659/6/22)

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Key facts

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Case	AUTH/3659/6/22
Parties	Complainant v Teva
Company	Teva UK Limited
Product	Ajovy (fremanezumab)
Material	HCP registration website for recorded webinar highlights (lessmigraine.co.uk; ref AJO-UK-00016; Date of Preparation: October 2020)
Applicable Code	2021
Complaint received	15 June 2022
Case completed	19 June 2023
Appeal	No appeal
Breach clauses	5.1, 12.6, 12.10, 16.1
No breach clauses	2, 3.6, 5.1, 6.1, 6.2, 11.2, 26.2
Sanctions	Undertaking received; Additional sanctions: Not stated

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

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An anonymous, contactable complainant (self-described health professional) complained about a Teva UK registration website for HCPs to access recorded webinar highlights about Ajovy (fremanezumab): lessmigraine.co.uk (ref AJO-UK-00016; Date of Preparation: October 2020).
Allegations included: lack of a “public” option on the landing page; alleged disguised promotion; alleged off-label promotion via “difficult-to-treat migraine” wording; missing black triangle at first mention of Ajovy; “Less migraine. More moments.” as a hanging comparison; and lack of a prominent prescribing information (PI) statement/link.
The Panel found that promotional content on the registration website was accessible before HCP status was checked/confirmed (ie, before secure login details were issued).
The PI link was placed in the footer in smaller font alongside privacy policy/terms, and was not sufficiently prominent.
The black triangle was not adjacent to the first mention of Ajovy on the homepage and registration page; the logo with black triangle was in the footer and likely required scrolling.

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Breach found for: Clause 5.1, Clause 12.6, Clause 12.10, Clause 16.1.
No breach found for: Clauses 2, 3.6, 5.1 (in relation to black triangle issues), 6.1, 6.2, 11.2, 26.2.
No breach of off-label promotion (Clause 11.2) was found on the narrow allegations presented; the Panel noted SPC section 5.1 included a study titled “Difficult to treat migraine” and the complainant did not establish otherwise.
No breach of disguised promotion (Clause 3.6) was found in the particular circumstances; the landing page stated it was funded and organised by Teva UK Limited and HCPs would likely assume it included promotional content.

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Breach of Clause 5.1 Failing to maintain high standards
Breach of Clause 12.6 Failing to include a clear, prominent statement as to where prescribing information could be found
Breach of Clause 12.10 Failing to include a black triangle adjacent to the first mention of the product in digital material
Breach of Clause 16.1 Producing a website that contained promotional material which did not comply with all relevant requirements of the Code
No Breach of Clause 2 Requirement that activities or material must not bring discredit upon, or reduce confidence in, the pharmaceutical industry
No Breach of Clause 3.6 Requirement that materials and activities must not be disguised promotion
No Breach of Clause 5.1 Requirement to maintain high standards
No Breach of Clause 6.1 Requirement that claims must not be misleading
No Breach of Clause 6.2 Requirement that claims must be capable of substantiation
No Breach of Clause 11.2 Requirement that a medicine must be promoted in accordance with the terms of its marketing authorisation and must not be inconsistent with the particulars listed in its summary of product characteristics
No Breach of Clause 26.2 Requirement that information about prescription only medicines which is made available to the public must be factual, balanced, must not raise unfounded hopes of successful treatment or encourage the public to ask their health professional to prescribe a specific prescription only medicine.

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