GSK: Senior medical employee ‘loved’ LinkedIn post seen as disseminating off-label promotion for Jemperli (AUTH/3690/8/22)

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Key facts

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Case number	AUTH/3690/8/22
Company	GlaxoSmithKline (GSK)
Product	dostarlimab (Jemperli)
Channel	LinkedIn (employee “love” reaction to third-party post)
Complainant	Non-contactable complainant; described self as a concerned health professional
Core issue	Employee engagement treated as proactive dissemination; off-label promotion risk (rectal cancer vs authorised indication)
Employee connections	~2,100 connections; >95% estimated health professionals; ~1,200 UK-based
SPC indication referenced by Panel	Monotherapy for adult patients with dMMR/MSI-H recurrent or advanced endometrial cancer that has progressed on/following platinum-containing regimen
Breach clauses	Clause 5.1; Clause 11.2
No breach clauses	Clause 2; Clause 3.1
Sanctions	Undertaking received
Complaint received	6 September 2022
Case completed	17 August 2023
Applicable Code year	2021
Appeal	No appeal

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

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A non-contactable complainant (described as a concerned health professional) complained about a UK-based senior medical GSK employee reacting “loves this” to a LinkedIn post from a renowned cancer institution.
The post referenced ASCO 2022/NEJM and linked to content about immunotherapy in rectal cancer; the linked article mentioned “dostarlimab (Jemperli)” once and described its use in rectal cancer.
The employee had ~2,100 LinkedIn connections; GSK estimated >95% were health professionals, with ~1,200 UK-based connections.
The Panel considered that “liking/loving” a post increases the likelihood it appears in connections’ feeds (eg, “[name] likes this”) and can therefore amount to proactive dissemination, bringing the material within scope of the UK Code.
Jemperli had a UK marketing authorisation, but for a different indication (endometrial cancer); the post/article related to rectal cancer (outside the MA).
GSK stated it was not involved in creating or distributing the external post and it was not certified by a GSK signatory.
GSK said the employee “unloved” the post, repeated social media training, and GSK committed to update policies/training to better address indirect promotion even without explicit product mention.

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Breach of Clause 5.1 (Failing to maintain high standards).
Breach of Clause 11.2 (Promotion inconsistent with the summary of product characteristics).
No breach of Clause 2 (Requirement that activities or materials must not bring discredit upon, or reduce confidence in, the pharmaceutical industry).
No breach of Clause 3.1 (Requirement that a medicine must not be promoted prior to the grant of its marketing authorisation) because Jemperli already had a marketing authorisation (albeit for a different indication).

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Breach of Clause 5.1 Failing to maintain high standards
Breach of Clause 11.2 Promotion inconsistent with the summary of product characteristics
No Breach of Clause 2 Requirement that activities or materials must not bring discredit upon, or reduce confidence in, the pharmaceutical industry
No Breach of Clause 3.1 Requirement that a medicine must not be promoted prior to the grant of its marketing authorisation

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