Novo Nordisk voluntary admission: failure to appropriately certify collaborative working website hub (AUTH/3738/2/23)

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Key facts

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Case number	AUTH/3738/2/23
Company	Novo Nordisk Ltd
Matter	Failure to appropriately certify a weight management and obesity hub hosted on an association website (collaborative working material)
Channel	Password-protected website hub on a third-party (association) site
Applicable Code year	2021
Complaint received	14 February 2023
Case completed	30 October 2023
Appeal	No appeal
Versions referenced	4 versions (v1 certified 17/03/22; v2 certified 10/05/22; v3 certified 04/08/22; v4 certified 12/10/22). Certification failures related to versions 2–4.
Key issue	Certified PDFs in PromoMats did not exactly match the live hub; changes were made to live content pre- and post-certification, including a YouTube link added without Novo Nordisk’s knowledge
Hub taken down	25 November 2022
Clause findings	Breach: 8.3, 5.1; No breach: 2
Sanctions	Undertaking received; Additional sanctions: Not stated

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

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What happened

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Novo Nordisk made a voluntary admission after an internal investigation linked to Case AUTH/3711/11/22.
The issue concerned a weight management and obesity “hub” hosted on a named UK pharmacists’ association website, developed as part of a collaborative working project.
The hub was accessible to association members via username/password; Novo Nordisk said it had no control over other parts of the association’s website.
There were four versions of the hub (March–October 2022). Novo Nordisk admitted failures in its certification process for versions 2–4.
Key failures included: changes being made to the live site when Novo Nordisk expected offline changes prior to certification; and mismatches between the certified PDFs in PromoMats and the live hub.
Some post-certification changes were made by the association alone, and some with direction from Novo Nordisk.
A change to version 2 was made without Novo Nordisk’s knowledge: a link to a YouTube video was added (10 June 2022) and later removed (3 August 2022).
Signatories believed they were certifying an offline/private version for version 4, but later learned they had been reviewing the live version.
Novo Nordisk believed the hub was offline during part of the update period (23 Sept–11 Oct 2022), but the association later confirmed it was live.
The hub was removed from the association website on 25 November 2022 following the complaint received in Case AUTH/3711/11/22 (received 23 November 2022). The collaborative working project was being terminated.

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Outcome

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Breach of Clause 8.3 (Failing to certify material relating to collaborative working).
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 appeal.

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Key facts

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