AUTH/3800/7/23: Employee complaint alleging MEGS used to promote Imfinzi (No breach)

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Key facts

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Case	AUTH/3800/7/23
Complainant	Contactable complainant who described themselves as an AstraZeneca UK Limited employee (later became non-contactable)
Company	AstraZeneca
Medicine	Imfinzi
Activity at issue	MEGS programme “Auxilium CRT” (Chemo-Radiation Therapy support/education)
Main allegation	MEGS used as disguised promotion/inducement to boost Imfinzi; plus poor compliance culture
Applicable Code year	2019
Clauses considered	Clause 2; Clause 9.1; Clause 12.1; Clause 19.1; Clause 19.2
Outcome	No breach of the Code
Appeal	No appeal
Complaint received	22 July 2023
Case completed	1 July 2024
Source	https://www.pmcpa.org.uk/cases/completed-cases/auth3800723-employee-v-astrazeneca

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

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An AstraZeneca employee complained that during Oct 2020 (COVID-19 period) AstraZeneca Oncology used a Medical and Educational Goods and Services (MEGS) programme (“Auxilium CRT”) to promote Imfinzi, described as an “underperforming” product.
The complainant alleged the MEGS was targeted at “underperforming centres” (centres not using enough Imfinzi) and that senior leaders pushed ahead despite medical/compliance concerns.
The complainant cited internal emails and a slide deck titled “Imfinzi – ideas to boost performance” and alleged this showed disguised promotion and a poor compliance culture.
AstraZeneca said Auxilium CRT was a non-promotional MEGS designed to support patients and clinicians around chemo-radiation therapy (CRT) in stage III NSCLC, approved internally in March 2020 (before the Oct 2020 idea-generating meeting referenced in the complaint).
AstraZeneca said field briefing documents explicitly instructed that the MEGS must not be discussed alongside Imfinzi and must not be linked to brand; and that KPIs/reporting for the service provider were not related to Imfinzi.
The Panel assessed the complaint under the 2019 Code (the relevant Code at the time) and split it into two broad allegations: (1) MEGS used to promote Imfinzi/disguised promotion/inducement; (2) poor culture/high standards and industry discredit allegations linked to the above.

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