CSL Vifor voluntary admission: uncertified Ferinject banners shown to UK HCPs via ESC-HFA/Medscape (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
Conference / timing	ESC-HFA (May 2022); banners visible for 60 days
Product	Ferinject (ferric carboxymaltose)
Audience reach	276,669 health professionals across Europe; ~1/5 deliveries to UK health professionals
Engagement	275 clicks total; 57 clicks from UK health professionals
Core issue	Promotional material accessible to UK HCPs was not certified by UK nominated signatories; signatory details not notified in advance to MHRA/PMCPA
Applicable Code year	2021
Breach clauses	5.1, 8.1, 8.4
Sanctions	Undertaking received
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 banner activity sat within a Notice of Commission (NoC) (dated 10 December 2021) covering nine activities; the banner was under a “Conference Package”.
Unlike other NoC activities that listed specific target countries, the “Conference Package” referred to targeting the third party network “in Europe” (described by CSL Vifor as an involuntary drafting error).
The campaign was intended to cover 11 countries and exclude the UK, but the third party 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 made no assessment of the content of the banners (content compliance was not the subject of the voluntary admission).
No appeal.

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