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
Complaint	Allegations about conduct on LinkedIn (employee ‘likes’/dissemination; promotion to public; unlicensed combinations; pre-authorisation promotion)
Complainant	Anonymous, contactable complainant who described themselves as an AstraZeneca employee (later non-contactable)
Code year applied	2019
Platforms/material	LinkedIn posts and linked press releases
Products referenced	Imfinzi (durvalumab); domvanalimab (third-party investigational anti-TIGIT); tremelimumab (in development at the time)
Key conduct	UK-based senior employees ‘liked’ promotional posts about Imfinzi combinations and trial results, disseminating to connections likely including the public
Breach findings	Clause 2; Clause 3.1; Clause 9.1 (x3); Clause 26.1 (x2)
No breach	No Breach of Clause 3.1 (re domvanalimab not being an AstraZeneca molecule)
Sanctions	Undertaking received; Additional sanctions: Advertisement
Complaint received	6 June 2023
Case completed	21 October 2024
Appeal	No appeal

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

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An anonymous, contactable complainant (later non-contactable) alleged non-compliant LinkedIn activity by senior global UK-based AstraZeneca employees, involving ‘likes’/‘shares’ that amounted to promotion to the public.
Two historical LinkedIn posts were cited: (1) an October 2020 third-party post about a Phase 3 trial of domvanalimab (anti-TIGIT) plus Imfinzi in unresectable Stage III NSCLC, ‘liked’ by two UK-based AstraZeneca employees; (2) a May 2021 post (made by a US-based AstraZeneca employee) about POSEIDON results (Imfinzi + tremelimumab + chemotherapy) ‘liked’ by a UK-based AstraZeneca employee.
AstraZeneca asked the employees to withdraw their ‘likes’; this was done immediately.
The Panel considered that ‘liking’ proactively disseminated the content to the employees’ LinkedIn connections (500+ each), likely including members of the public, bringing the material within scope of the UK Code.
The Panel viewed both posts (and linked press releases) as promotional in tone (eg, “promising immunotherapy combination”, “overall survival benefit”, “clinically meaningful”).
The Panel did not make rulings on the complainant’s broader allegation that compliance requests to ‘unlike’ posts were repeatedly ignored, because the complainant did not discharge the burden of proof.

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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 (in relation to tremelimumab).
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 (Imfinzi).
No breach of Clause 3.1 Requirement that a medicine must not be promoted prior to the grant of its marketing authorisation (in relation to domvanalimab, which was not an AstraZeneca molecule).

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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
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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