AUTH/3797/7/23: Complainant v Besins Healthcare — alleged disguised promotion on Besins Hormone Academy website (No breach)

📊

Key facts

⌄

Case number	AUTH/3797/7/23
Company	Besins Healthcare (UK) Ltd
Complainant	Concerned health professional
Allegation	Disguised promotion on three webpages of the Besins Hormone Academy website
Material/channel	Website pages (HCP-facing), linked to Menopause Roadshow 2023; referenced distribution via targeted emails, HCP journal banner adverts, and LinkedIn InMail
Applicable Code	2021
Clauses considered	Clause 5.1; Clause 15.6
Panel decision	No breach of Clause 5.1; No breach of Clause 15.6
Appeal	No appeal
Complaint received	6 July 2023
Case completed	16 September 2024
Sanctions	None

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

🤖

Got a question about this case?

Ask one of our 13 specialist ABPI advisors — instant answers, 24/7.

Ask AskAnzal AI

📋

⌄

A health professional complained about three webpages on the “Besins Hormone Academy” website, alleging the promotional nature was disguised because the site did not explicitly state it was promotional.
The complainant pointed to an “Our programmes” page and a Menopause Roadshow page where a link to Prescribing Information appeared, and noted an adverse event reporting statement appeared across pages.
PMCPA initially cited Clause 5.6 in correspondence, then corrected this to Clause 15.6; Besins agreed the complaint could be considered under Clause 15.6.
Besins said the site was intended for UK healthcare professionals only, with a landing page asking users to confirm whether they were an HCP or a member of the public, and a prominent HCP-only banner on each page.
Besins stated the site supported registration for “Menopause Roadshow 2023” meetings, which it categorised as promotional; HCPs were directed to the site via certified invitations (emails, banner adverts in HCP journals, and LinkedIn InMail) that included clear declarations that Besins medicines would be discussed.
Besins said the site was not search engine optimised and not actively promoted online as a standalone destination.
Besins suspended the website while the matter was investigated and resolved.

⚖️

⌄

No breach of Clause 15.6 (Promotional material and activities must not be disguised).
No breach of Clause 5.1 (high standards must be maintained at all times).
No appeal.

🔒

Members get the complete breakdown — Clauses, Sanction, Signatory Lens, Audit checklist, and 3 Key Questions.

Best value

£249/year

Annual — save £99

£29/mo

Monthly

Join Now — Instant Access