AstraZeneca: promotional meeting misclassified and LinkedIn ‘likes/reposts’ led to pre-authorisation promotion and public advertising concerns (AUTH/3729/1/23)

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Key facts

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Case	AUTH/3729/1/23
Company	AstraZeneca UK Limited
Complainant	Complainant/s (described themselves as ex-employee/s)
Issues	Alleged promotional activities across a UK meeting and LinkedIn activity; additional allegations about MSL pressure and Early Access Programmes
Complaint received	14 December 2022
Case completed	22 July 2024
Appeal	No appeal
Applicable Code year	2021 (Complaint 2 ruled under representative clauses in the 2019 Code)
Medicines mentioned	Tagrisso (osimertinib); Iressa/gefitinib; capivasertib; Imfinzi (durvalumab); olaparib (OlympiA EAP); acalabrutinib
Sanctions	Undertaking received; Additional sanctions: Advertisement

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

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What happened

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Complaint 1 (Jan 2022 webinar): A virtual “Early Stage Think Tank” meeting (described as non-promotional) included discussion of Tagrisso (osimertinib) and gefitinib trial data; the Panel considered the meeting promotional and found issues including lack of certification/PI and use of “cure” on slides.
Complaint 2 (LinkedIn posts, Mar/May 2021): Two LinkedIn posts about Tagrisso and acalabrutinib were alleged to be public promotion; AstraZeneca said they were posted before the individual joined AstraZeneca.
Complaint 3 (LinkedIn likes/repost): UK-based AstraZeneca employees “liked” and reposted a third-party research institute’s LinkedIn posts describing capivasertib’s “remarkable benefits” and linking to more trial information; capivasertib did not have a UK marketing authorisation at the time.
Complaint 4 (LinkedIn like): A UK-based employee “liked” a LinkedIn post sharing an article and survival graph about Tagrisso; the Panel treated the “like” as proactive dissemination to the employee’s connections, including members of the public.
Complaint 5 (MSLs/account reviews): Allegations that MSLs were pressured to promote Imfinzi (durvalumab) off-label during quarterly account review meetings and that Medical activity was being directed by commercial.
Complaint 6 (Early Access Programme): Allegations that the OlympiA olaparib Early Access Programme was used as a seeding/disguised promotion programme and that Medical teams were encouraged to promote it prior to authorisation/reimbursement.

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Outcome

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Complaint 1: Breach of Clause 5.1 (x3); Breach of Clause 6.1 (x2); Breach of Clause 8.1. No breach of Clause 2, Clause 3.1, Clause 5.2, Clause 15.6 (and no breach findings also recorded for Clause 5.1 and Clause 6.1 as listed in the case summary).
Complaint 2 (2019 Code): No breach of Clause 2, Clause 9.1, Clause 12.1, Clause 14.1, Clause 26.1.
Complaint 3: Breach of Clause 2; Breach of Clause 3.1; Breach of Clause 5.1. No breach of Clause 26.1.
Complaint 4: Breach of Clause 5.1; Breach of Clause 26.1. No breach of Clause 2.
Complaint 5: No breach of Clause 5.1; No breach of Clause 17.2; No breach of Clause 17.9.
Complaint 6: No breach of Clause 5.1; No breach of Clause 11.1; No breach of Clause 17.9.

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