Takeda UK: supplier payment-terms letter contained promotional claims and pre-authorisation content (AUTH/3742/2/23)

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Key facts

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Case number	AUTH/3742/2/23
Company	Takeda UK Limited
Type	Voluntary admission
Issue	Promotion to the public; pre-authorisation promotion; uncertified promotional material in a supplier payment-terms letter
Applicable Code year	2021
Audience	266 UK-based suppliers (mostly general business services/public) and a small number of HCOs (including homecare service companies)
Material	Letter about new global payment terms
Products/asset referenced	Livtencity, Exkivity, Qdenga; plus an in-licensed molecule/asset in clinical development (potential indications mentioned: psoriasis, IBD, lupus)
Key compliance failures	Promotional language to public; pre-authorisation content; lack of certification; high standards not maintained
Breach clauses	3.1, 5.1, 8.1, 11.1, 26.1
Sanctions	Undertaking received; additional sanctions not stated
Complaint received	16 February 2023
Case completed	29 November 2023
Appeal	No appeal

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

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Takeda UK made a voluntary admission about a letter sent to 266 UK-based suppliers (7 February 2023) about new global payment terms.
The letter was created and distributed by Takeda’s Global Procurement Office (Boston, USA) and was not reviewed or approved by any Takeda UK employee before distribution.
Recipients were mostly providers of general business services (treated as members of the public) and a small number of healthcare organisations (HCOs), including homecare service companies.
The letter included promotional language and references to three licensed medicines (Livtencity, Exkivity, Qdenga) and a recently acquired asset still in clinical development, including potential future indications (psoriasis, IBD, lupus).
Promotional phrasing included: “life-transforming treatments”, “new hope”, “potential to significantly improve”, and “promising”.

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Breach found (multiple clauses) following Takeda’s voluntary admission.
The Panel ruled the letter was promotional, had been sent to the public and to HCOs, included pre-authorisation promotion, and had not been certified.
No appeal.
Undertaking received.

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Breach of Clause 3.1 Promotion of a medicine prior to the grant of its marketing authorisation
Breach of Clause 5.1 Failing to maintain high standards
Breach of Clause 8.1 Failing to certify promotional material
Breach of Clause 11.1 Promotion of a medicine prior to the grant of its marketing authorisation
Breach of Clause 26.1 Advertising a prescription only medicine to the public

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