Novo Nordisk: booking form for third‑party training still accessible online after undertaking (AUTH/3754/3/23)

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Key facts

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Case	AUTH/3754/3/23
Parties	Health Professional/Director v Novo Nordisk
Issue	Alleged breach of undertaking relating to an online booking form for third-party training previously ruled in breach (AUTH/3525/6/21)
Material	Booking form describing a training webinar and eligible health professionals
How found	Google search using a specific term: “Free Weight Management Course (WEBINAR + PGD”
Applicable Code	2021
Complaint received	18 March 2023
Case completed	22 November 2023
Appeal	No appeal
Breach findings	Clause 3.3; Clause 5.1
No breach	Clause 2
Sanctions noted	Undertaking received; Additional sanctions (details not stated)

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

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A concerned health professional found that a booking form for a “Free Weight Management Course (WEBINAR + PGD)” was still accessible online via a specific Google search term.
The form related to training previously found in breach in Case AUTH/3525/6/21 (third-party LinkedIn post and associated training considered promotional for Saxenda, for which Novo Nordisk was responsible).
The complaint was treated as an alleged breach of undertaking; the Director took it up because the PMCPA monitors compliance with undertakings.
Novo Nordisk described multiple steps (from June–November 2022) to get the third-party training provider to remove references/links, including requests to remove sponsorship mentions, LinkedIn posts, metadata, and “hidden” pages.
The Panel questioned whether Novo Nordisk acted with sufficient urgency and whether “all possible steps” had truly been taken, given gaps/time lags and limited evidence of persistent escalation beyond emails/voicemails.
The Panel found the booking form was still live and accessible, meaning the material found in breach in AUTH/3525/6/21 remained available.

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Breach of Clause 3.3 (Failing to comply with an undertaking).
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), given the specific circumstances (third party involvement and access via a very specific search term) and that concerns were adequately covered by Clauses 3.3 and 5.1.
No appeal.

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