AUTH/3744/2/23: Boehringer Ingelheim—Broken prescribing information link on promotional website (Pradaxa/Praxbind)

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Key facts

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Case number	AUTH/3744/2/23
Company	Boehringer Ingelheim Limited
Complainant	Anonymous, contactable complainant
Issue	Technical error: non-functioning prescribing information link on a promotional webpage
Product(s)	Pradaxa and Praxbind
Channel	Promotional website/webpage hosted by a third party (“Chronic Conditions”)
Period PI link not functional	7 February 2023 to 28 February 2023
Complainant email to company	13 February 2023 (treated as spam and deleted)
Complaint received by PMCPA	23 February 2023
Applicable Code	2021
Breach clauses	5.1, 12.1, 12.4
Appeal	No appeal
Sanctions	Undertaking received; Additional sanctions: Not stated
Case completed	19 January 2024

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

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A promotional webpage on a third-party hosted site (“Chronic Conditions”) included a single-click link to prescribing information (PI) for Pradaxa and Praxbind.
The PI link stopped working from 7 February 2023 to 28 February 2023.
The complainant emailed Boehringer Ingelheim’s medical information mailbox on 13 February 2023 warning the PI link did not work and urging urgent action.
The email was incorrectly flagged as spam/phishing and deleted by the assistant monitoring the mailbox, so it was not actioned.
Boehringer Ingelheim had decided in January 2023 to retire Pradaxa promotional materials; the PI and webpage were retired on 7 February, but the third party was not informed (human error), leaving the page live with a broken PI link.
After the PMCPA letter (dated 24 February 2023), the company asked the third party to take the page down; it was deactivated on 28 February 2023 and double-checked.

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Breach of Clause 12.1 (prescribing information not provided in promotional material).
Breach of Clause 12.4 (digital material did not provide PI via a clear, prominent, direct single-click link).
Breach of Clause 5.1 (failure to maintain high standards), including concern that an email titled “Technical error with your PI link” sent to medical information was treated as spam and deleted.
No appeal.

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