Novo Nordisk breached Clause 5.5 over unclear involvement in pharmacist obesity hub and documents (AUTH/3711/11/22)

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Key facts

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Case	AUTH/3711/11/22
Company	Novo Nordisk Ltd
Complainant	Contactable complainant (concerned UK health professional)
Subject	Weight management and obesity hub on a pharmacist association website; associated downloadable documents; allegations about training links
Applicable Code	2021
Complaint received	21 November 2022
Case completed	09 March 2023
Appeal	No appeal
Breach clauses	Clause 5.5; Clause 5.1
No breach clauses	Clauses 2, 3.3, 5.1, 5.5, 8.1, 12.1, 15.6 (as listed in the case summary for specific allegations/documents)
Sanctions	Undertaking received; Additional sanctions: Not stated
Key issue	Disclosure of the company’s exact involvement was not sufficiently clear and prominent at the outset on the hub and four documents

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

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A UK health professional complained about a password-protected weight management and obesity “hub” hosted on a UK pharmacist association’s website, developed under a Collaborative Working (CW) project with Novo Nordisk (CW started December 2021).
The complainant alleged the hub and associated materials did not clearly state Novo Nordisk’s level of involvement and were intended to promote Novo Nordisk’s product (Saxenda), including via training links and PGD-related content.
The hub included a declaration near the top stating the association and Novo Nordisk were “working collaboratively” to support pharmacies, but (per the Panel) did not clearly explain the extent of Novo Nordisk’s involvement (eg funding and co-creation) at the outset.
The Panel could not access the hub directly (password protected) and relied on evidence provided, including Novo Nordisk’s certified PDF of the hub (ref UK22OB00237, certified 11 October 2022) and the complainant’s cropped screenshots.
Novo Nordisk stated links to a named training provider’s course (previously associated with Case AUTH/3525/6/21) had been removed from the hub by 6 October 2022, before the undertaking in that earlier case was returned (12 October 2022).
The Panel assessed whether the hub and downloadable documents clearly declared Novo Nordisk’s role, and whether materials were promotional/disguised promotion and required prescribing information/certification.

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Breach: Clause 5.5 (hub page and four documents) for failing to be sufficiently clear about Novo Nordisk’s exact role and involvement at the outset.
Breach: Clause 5.1 for failing to maintain high standards (driven by multiple Clause 5.5 failures).
No breach: Clause 3.3 (undertaking) and consequently no breach of Clauses 5.1 and 2 in that regard.
No breach: Clauses 8.1 and 12.1 (Panel did not accept the documents were promotional or required prescribing information).
No breach: Clause 15.6 (not established that the hub/documents were disguised promotion at the time of complaint).
No breach: Clause 2 (Panel did not consider the circumstances warranted particular censure).

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Breach of Clause 5.5 Failing to be sufficiently clear as to the company’s role and involvement
Breach of Clause 5.1 Failing to maintain high standards
No Breach of Clause 5.5 Requirement to be sufficiently clear as to the company’s role and involvement
No Breach of Clause 15.6 Requirement that promotional materials and activities must not be disguised
No Breach of Clause 8.1 Requirement to certify promotional material
No Breach of Clause 12.1 Requirement to include prescribing information
No Breach of Clause 5.1 Requirement to maintain high standards
No Breach of Clause 3.3 Requirement to comply with an undertaking
No Breach of Clause 2 Requirement that activities or material must not bring discredit upon, or reduce confidence in, the pharmaceutical industry

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