Pfizer UK tweets linking to Pulse Today sponsored article: audience not stated and governance concerns (AUTH/3721/1/23)

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Key facts

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Case	AUTH/3721/1/23
Parties	Complainant v Pfizer
Issue	Allegations about Pfizer UK tweets linking to a Pulse Today sponsored article; audience labelling and governance; alleged promotion/obligatory info/POM advertising to public
Channel	Twitter/X (Pfizer UK account) linking to Pulse Today online article
Content referenced	Pulse Today sponsored article: “Adopting a prevention-first mindset this winter” (authored by a senior Pfizer medical employee)
Applicable Code year	2021
Complaint received	3 January 2023
Case completed	4 March 2024
Appeal	No appeal
Breach clauses	5.1
No breach clauses	2, 12.1, 12.2, 12.4, 12.10, 26.1
Sanctions	Undertaking received; Additional sanctions: Not stated

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

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Pfizer UK posted a series of three tweets (Dec 2022) from the public @Pfizer_UK account linking to a Pulse Today online article titled “Adopting a prevention-first mindset this winter”.
The linked page carried a header stating it was intended for health professionals only and the article was labelled: “Sponsored Content: This content has been developed and paid for by Pfizer UK.”
The complainant alleged the article promoted Pfizer’s COVID-19 and pneumococcal vaccines (without naming them) and therefore required Clause 12 obligatory information, and that linking to it from a public Twitter feed amounted to advertising POMs to the public (Clause 26.1).
Pfizer said the article was non-promotional, discussed vaccination in general across multiple respiratory diseases, and the tweets were organic (not paid/targeted). Pfizer accepted a “human error” in not marking the tweets for healthcare professionals.
The Panel considered the tweets in the context of the linked article and referenced PMCPA Social Media Guidance 2023 on signposting, audience clarity, and linked material being part of the post.

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Breach: Clause 5.1 (Failing to maintain high standards).
No breach: Clauses 2, 12.1, 12.2, 12.4, 12.10, 26.1.
The Panel did not consider the complainant had established (on balance) that the linked article was promotional.
The Panel’s key concern was that the intended audience was omitted from the tweets and internal governance/approval was poor (including an approval form listing the audience as “General Public”).

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Breach of Clause 5.1 Failing to maintain high standards
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 12.1 Requirement to provide prescribing information in promotional material
No Breach of Clause 12.2 Requirement that the prescribing information includes the specified information
No Breach of Clause 12.4 Requirement to provide prescribing information in digital material
No Breach of Clause 12.10 Requirement to include the black triangle in promotional material
No Breach of Clause 26.1 Requirement to not advertise prescription only medicines to the public

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