GSK value.gsk COPD landing page: charts misleading because asthma data caveat was hidden in a dropdown (Clause 6.1 breach)

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Key facts

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Case	AUTH/3792/7/23
Company	GSK UK Ltd
Complainant	Anonymous, contactable complainant (health professional)
Material	Landing page of GSK promotional website (value.gsk) relating to COPD medicines optimisation
Products mentioned	Trelegy Ellipta; Anoro Ellipta; Relvar Ellipta; Incruse Ellipta; Seretide Accuhaler
Main upheld issue	Charts were misleading because the caveat that certain LAMA products can also be used for asthma (opportunity estimated only) was only available via a dropdown, not integral to the charts
Applicable Code year	2021
Breach	Clause 6.1 (x2)
No breach	Clause 2 (x4); Clause 5.1 (x4); Clause 6.1 (as ruled for other aspects); Clause 6.2 (x3); Clause 11.2 (x5)
Sanctions	Undertaking received
Complaint received	4 July 2023
Case completed	2 December 2024
Appeal	No appeal

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

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An anonymous, contactable health professional complained about the landing page of GSK’s value.gsk promotional website for COPD medicines optimisation.
The page listed five GSK respiratory products (Trelegy Ellipta, Anoro Ellipta, Relvar Ellipta, Incruse Ellipta, Seretide Accuhaler) and provided links to prescribing information.
The complainant alleged (among other points) that:
- Relvar has two strengths and 184/22 is not licensed for COPD, but the page only said “Relvar”, risking incorrect assumptions.
- Listing the five products in a COPD context without specific indications implied they were licensed for any COPD patient (off-licence promotion).
- Charts labelled as COPD prescribing trends were misleading because the LAMA segment also included asthma data; the caveat (“Certain LAMA products can also be used for Asthma, opportunity is estimated only”) was only visible by expanding a “calculations and assumptions” dropdown.
The Panel accepted the site’s purpose was to support payers/ORDMs and population-level COPD medicines optimisation (not individual patient prescribing decisions).

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Breach of Clause 6.1 (x2) (misleading information) in relation to the charts (pie charts and bar charts) because highly pertinent qualifying information was not integral to the charts and required a dropdown click.
No breach of Clause 6.1 (in relation to Relvar strength/implication point).
No breach of Clause 6.2 (x3) (substantiation) including for the charts.
No breach of Clause 11.2 (x5) (promotion consistent with marketing authorisation) for each of the five medicines listed.
No breach of Clause 5.1 (x4) (high standards) and No breach of Clause 2 (x4) (discredit) across the allegations.

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