AstraZeneca: employees’ LinkedIn ‘likes’ treated as public promotion of POMs (AUTH/3784/6/23)

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Key facts

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Case	AUTH/3784/6/23
Company	AstraZeneca
Issue	Alleged promotion to the public of AstraZeneca portfolio on LinkedIn (employee ‘likes’ of third-party post)
Platform	LinkedIn
Medicines named	Tagrisso, Lynparza, Enhertu, Calquence
Employees involved	14 UK-based AstraZeneca Global employees ‘liked’ the post
Key Panel finding	Original third-party post out of scope, but employees’ engagement brought it into scope; ‘likes’ disseminated promotional POM content to connections likely including the public
Applicable Code year	2021
Breaches	Clause 5.1; Clause 26.1
No breach	Clause 2; Clause 26.2
Sanctions	Undertaking received; additional sanctions not stated
Complaint received	23 June 2023
Case completed	20 August 2024
Appeal	No appeal

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

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A third party posted on LinkedIn naming four AstraZeneca oncology medicines: Tagrisso, Lynparza, Enhertu and Calquence.
The post included efficacy messaging (eg Tagrisso trial data “cut the risk of death by more than half…”), and described Calquence as a “blood cancer drug”.
The post contained links: one to a news article (full article behind a subscription paywall; Panel saw only the publicly available part) and one to a book publisher page (no medicines mentioned).
Two LinkedIn profiles were ‘mentioned’ in the post, including a senior AstraZeneca staff member.
14 UK-based AstraZeneca Global employees ‘liked’ the post (initially 6 identified by the complainant; AstraZeneca later found 8 more).
AstraZeneca contacted the employees and asked them to withdraw their ‘likes’ immediately and re-familiarise themselves with its global social media standard.
AstraZeneca stated all 14 had completed annual Code of Ethics Awareness training; all but one had read and signed the Global Standard on employee social media use at the time of the post.
The Panel decided the Code did not apply to the original third-party post, but did apply to employees’ engagement because it proactively disseminated the post to their UK connections (likely including members of the public).

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Breach of Clause 5.1 (Failing to maintain high standards).
Breach of Clause 26.1 (Advertising a prescription only medicine to the public).
No breach of Clause 2 (Requirement that activities of materials must not bring discredit upon, or reduce confidence in, the pharmaceutical industry).
No breach of Clause 26.2 (Requirement that information about prescription only medicines which is made available to the public must be factual, balanced, must not raise unfounded hopes of successful treatment or encourage the public to ask their health professional to prescribe a specific prescription only medicine).
No appeal.

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