AstraZeneca: Senior UK-based employees’ LinkedIn ‘likes’ treated as promotional dissemination to the public (AUTH/3774/6/23)

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Key facts

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Case	AUTH/3774/6/23
Company	AstraZeneca
Issue	Senior UK-based employees ‘liking’ LinkedIn posts linking to promotional press releases about Imfinzi combinations and trial results
Platform	LinkedIn
Products mentioned	Imfinzi (durvalumab); tremelimumab; domvanalimab (third-party investigational product)
Key conduct	‘Liking’ posts treated as proactive dissemination to connections likely including the public
Applicable Code year	2019
Complaint received	6 June 2023
Case completed	21 October 2024
Appeal	No appeal
Breaches	Clause 2; Clause 3.1; Clause 9.1 (x3); Clause 26.1 (x2)
No breach	Clause 3.1 (in relation to domvanalimab not being an AstraZeneca molecule)
Sanctions applied	Undertaking received; Advertisement

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

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An anonymous, contactable complainant (who later became non-contactable) complained about senior global UK-based AstraZeneca employees’ activity on LinkedIn.
Two historical LinkedIn posts were cited:
- October 2020: a third-party CEO post about a Phase 3 trial of domvanalimab (anti-TIGIT) plus Imfinzi in unresectable Stage III NSCLC, linking to a third-party press release (including an AstraZeneca quote). Two senior UK-based AstraZeneca employees ‘liked’ it.
- May 2021: a post (AstraZeneca said it was by a US-based AstraZeneca employee) about POSEIDON results (Imfinzi + tremelimumab + chemotherapy) with a link to an AstraZeneca press release. A senior UK-based AstraZeneca employee ‘liked’ it.
The Panel considered that ‘liking’ the posts proactively disseminated the content to the UK-based employees’ LinkedIn connections (each had 500+ connections), likely including members of the public, bringing the material within scope of the UK Code.
The Panel did not make rulings on the complainant’s broader allegation of repeated refusals to ‘unlike’ posts, because the complainant did not provide enough information to discharge the burden of proof.
The Panel noted AstraZeneca’s global social media standard prohibited engaging with product-related content (including liking/sharing/commenting), even if published on official AstraZeneca channels or third-party sources; the senior employees appeared to have acted contrary to that policy.

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Breach of Clause 2 Bringing discredit upon, and reducing confidence in, the pharmaceutical industry.
Breach of Clause 3.1 Promoting a medicine prior to the grant of its marketing authorisation.
Breach of Clause 9.1 (x3) Failing to maintain high standards.
Breach of Clause 26.1 (x2) Advertising a prescription only medicine to the public.
No Breach of Clause 3.1 Requirement that a medicine must not be promoted prior to the grant of its marketing authorisation.

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Clause 2 Bringing discredit upon, and reducing confidence in, the pharmaceutical industry
Clause 3.1 Promoting a medicine prior to the grant of its marketing authorisation
Clause 9.1 (x3) Failing to maintain high standards
Clause 26.1 (x2) Advertising a prescription only medicine to the public
Clause 3.1 Requirement that a medicine must not be promoted prior to the grant of its marketing authorisation (No breach)

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