AGB-Pharma: Adaflex promotional webpage accessible to the public via Google indexing (AUTH/3749/3/23)

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Key facts

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Case number	AUTH/3749/3/23
Parties	Complainant v AGB-Pharma
Product	Adaflex (melatonin)
Channel	Company website (promotional webpage)
Main issue	Promotional POM webpage accessible to the public due to Google indexing/direct link bypassing HCP pop-up
Complaint received	02 March 2023
Case completed	15 May 2024
Applicable Code year	2021
Breach clauses	Clause 16.1; Clause 26.1
Appeal	No appeal
Sanctions applied	Undertaking received; Additional sanctions: Not stated
Company response highlights	Site taken down within 2 hours; root cause analysis; pop-up implemented across access points; testing across browsers and geographies before relaunch

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

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A complainant reported a website that appeared to advertise a UK prescription-only medicine (Adaflex) without restriction and freely accessible to the public.
The Adaflex branded webpage included a logo, an image of a child sleeping, the phrase “Answers the call to sleep”, product introduction, patient population information, NHS price, and prescribing information with adverse event reporting and references.
AGB said the page was intended for healthcare professionals (HCPs) and was meant to be protected by an HCP confirmation pop-up (Yes = access Adaflex content; No = redirected to corporate site without Adaflex content).
AGB’s root cause analysis concluded Google had indexed the Adaflex content page, creating a direct URL that bypassed the HCP confirmation pop-up, allowing public access via search or direct URL entry.
AGB took the site down within 2 hours of receiving the complaint and initiated an investigation and corrective actions.
AGB stated the webpage had not been advertised and it did not use SEO, pay-per-click, or Google tools to encourage traffic.
Corrective actions described: review all entry/access routes to Adaflex content; implement pop-ups at each access point; conduct rigorous testing across browsers and geographies; not relaunch until testing completed.

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Breach of Clause 16.1: Producing promotional material about prescription only medicines directed to a UK audience, provided on the internet, which did not comply with all the relevant requirements of the Code.
Breach of Clause 26.1: Promoting a prescription only medicine to the public.
No appeal.

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