CSL Vifor voluntary admission: Ferinject conference banners shown to UK HCPs without UK certification (AUTH/3689/8/22)

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Key facts

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Case	AUTH/3689/8/22
Company	CSL Vifor
Type	Voluntary admission
Activity	Ferinject promotional banner sequence (5 banners) on ESC-HFA 2022 congress website and Medscape mobile apps
Therapy area / context	Cardiology conference (ESC-HFA), May 2022
Duration	60 days
Audience reach	276,669 health professionals across Europe; ~one fifth of deliveries to UK health professionals
Engagement	275 clicks total; 57 clicks from UK health professionals
Core issue	Promotional material accessible to UK health professionals without UK-nominated signatory certification and without advance notification of signatories to MHRA/PMCPA
Applicable Code	2021
Breach clauses	Clause 5.1; Clause 8.1; Clause 8.4
Sanctions	Undertaking received; Additional sanctions: Not stated
Complaint received	5 September 2022
Case completed	30 August 2023
Appeal	No appeal

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

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CSL Vifor made a voluntary admission about promotional activities linked to the European Society of Cardiology – Heart Failure Association (ESC-HFA) conference (May 2022).
A third party ran a sequence of five Ferinject (ferric carboxymaltose) promotional banners on the ESC-HFA 2022 congress website and Medscape mobile apps for 60 days.
Clicking the banners showed Ferinject prescribing information and a link to ESC Guidelines.
The campaign was intended to cover 11 countries (UK not included), but the “Conference Package” section of the Notice of Commission referred to targeting “Europe”, and the vendor used a pan-Europe list without confirming target countries.
The banners were delivered to 276,669 health professionals across Europe; about one fifth of deliveries were to UK health professionals.
There were 275 clicks in total, including 57 clicks from UK health professionals.
Because UK access was not anticipated, the materials were not certified by UK-nominated signatories and the relevant signatory details were not notified in advance to the MHRA and PMCPA.

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Breach of Clause 5.1 was ruled.
Breach of Clause 8.1 was ruled.
Breach of Clause 8.4 was ruled.
The Panel did not assess the content of the banners (the voluntary admission related to certification/controls rather than claims/content).
No appeal.

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