Roche: Mobile vs desktop webpage certification and alleged off-licence promotion (Kadcyla/Perjeta) – No breach (AUTH/3667/6/22) | PMCPA Case

📊

Key facts

⌄

Case number	AUTH/3667/6/22
Complainant	Anonymous, contactable health professional
Company	Roche Products Ltd
Medicines	Kadcyla (trastuzumab emtansine); Perjeta (pertuzumab)
Material/channel	Roche Resources website page (Congress and Meetings section), “Future Positive Lite” (ref M-GB-00005336; date of preparation November 2021)
Main issues alleged	(1) Mobile vs desktop rendering required separate certification; (2) meeting/video title implied broader HER2+ early breast cancer indications (off-licence promotion)
Applicable Code year	2021
Clauses considered	2, 5.1, 8.1, 11.2
Outcome	No breach of the Code
Complaint received	26 June 2022
Case completed	14 June 2023
Appeal	No appeal

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

🤖

Got a question about this case?

Ask one of our 13 specialist ABPI advisors — instant answers, 24/7.

Ask AskAnzal AI

🎬 Expert Video Walkthrough

🎬

Video walkthrough — coming for members

Subscribe now and get expert video analysis for every case as we publish them.

Subscribe — from £299/yr

📋

⌄

A health professional complained about a Roche Resources website page in the “Congresses and Meetings” section (“Future Positive Lite”; ref M-GB-00005336, date of preparation November 2021).
Allegation 1: the desktop and mobile versions looked different (desktop showed breadcrumb text “Resources > Congresses and Meetings > Future Positive Lite”; mobile showed a light blue bar instead). The complainant said the two versions should have been certified separately.
Allegation 2: a prominent title under the prescribing information—“Tailoring Treatment for Patients with HER-2 positive Early Breast Cancer”—was said to imply Kadcyla (trastuzumab emtansine) and Perjeta (pertuzumab) were indicated broadly in HER2+ early breast cancer (i.e., beyond their specific licensed indications).
Roche said the site was dynamically responsive; it certified for the primary intended device (desktop) and its SOP required signatories to check other commonly used devices at certification.
Roche argued the meeting title described a discussion about tailoring treatment, and the page included prominent links to prescribing information and adverse event reporting, plus contextual “Discussion Topics” and access guidance.

⚖️

⌄

No breach of Clause 8.1 (Requirement to certify promotional material).
No breach of Clause 11.2 (Requirement not to promote a medicine for an unlicensed indication).
No breach of Clause 5.1 (Requirement to maintain high standards) and Clause 2 (Requirement that material must not bring discredit upon, or reduce confidence in, the pharmaceutical industry) as consequential allegations.
No appeal.

📖

⌄

Clause 2 Requirement that material must not bring discredit upon, or reduce confidence in, the pharmaceutical industry – No breach
Clause 5.1 Requirement to maintain high standards – No breach
Clause 8.1 Requirement to certify promotional material – No breach
Clause 11.2 Requirement not to promote a medicine for an unlicensed indication – No breach

🔒

Members get the complete breakdown — Clauses, Sanction, Signatory Lens, Audit checklist, and 3 Key Questions.

Best value

£249/year

Annual — save £99

£29/mo

Monthly

Join Now — Instant Access