AUTH/3801/7/23: Complainant v AstraZeneca — LinkedIn ‘About’ section alleged public promotion (No breach)

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Key facts

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Case number	AUTH/3801/7/23
Company	AstraZeneca
Complainant	Anonymous, contactable initially; later non-contactable
Channel	LinkedIn (employee profile ‘About’ section)
Main allegation	Advertising/promoting POMs to the public and promotion prior to marketing authorisation via brand/indication/trial references in a senior leader’s LinkedIn ‘About’ section
Medicines mentioned in profile (examples)	Tagrisso, Imfinzi, Imjudo, Enhertu; also referenced: DATO-dxd, savolitinib, ceralasertib
Studies mentioned	HUDSON; ORCHARD
Applicable Code	2021
Clauses considered	2, 3.1, 3.3, 3.4, 5.1, 26.1, 26.2
Outcome	No breach of the Code
Complaint received	24 July 2023
Case completed	2 October 2024
Appeal	No appeal

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

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An anonymous complainant alleged a very senior UK-based AstraZeneca leader’s LinkedIn profile ‘About’ section referenced multiple AstraZeneca medicines by brand name (eg Tagrisso, Imfinzi, Imjudo) and described Imfinzi as a “$2+BN” product with indications.
The complainant alleged this amounted to advertising prescription-only medicines (POMs) to the public on LinkedIn and included promotion prior to marketing authorisation by referencing metastatic NSCLC and ongoing trials (HUDSON and ORCHARD).
AstraZeneca said the ‘About’ text was created independently by the employee (no company instruction/knowledge) and was not proactively disseminated like posts/likes/shares; users would need to actively search for the profile and often click “see more”/scroll to view the full text.
On receipt of the complaint, AstraZeneca said the employee immediately updated their profile to remove drug-related references while the case was pending.
The Panel reviewed how LinkedIn profiles can be accessed (including via search engines) and noted that profile content can be publicly visible depending on settings; it also referenced PMCPA social media guidance (2023) about limited product references in professional profile sections where access requires active searching and additional navigation.

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No breach of Clause 26.1 (not advertising POMs to the public).
No breach of Clause 26.2 (public information about POMs must be factual/balanced etc) — the Panel said the complainant did not make a specific allegation under this clause.
No breach of Clause 3.1 (no promotion prior to marketing authorisation) — because the Panel did not consider the ‘About’ section content to be “advertising”, it similarly did not consider it “promotion”.
No breach of Clause 3.3 (undertakings) — complainant did not cite a specific undertaking/case.
No breach of Clause 3.4 (compliance with applicable codes/laws/regulations) — consequential to no other breaches.
No breach of Clause 5.1 (high standards) — consequential to no other breaches.
No breach of Clause 2 (discredit/reduce confidence) — allegation relied on an unspecified prior undertaking; Panel found no breach of Clause 3.3.

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Clause 2 Requirement that activities or materials must not bring discredit upon, or reduce confidence in, the pharmaceutical industry
Clause 3.1 Requirement that a medicine must not be promoted prior to the grant of its marketing authorisation
Clause 3.3 Requirement to comply with an undertaking given in relation to a ruling under the Code
Clause 3.4 Requirement that companies must comply with all applicable codes, laws and regulations to which they are subject
Clause 5.1 Requirement to maintain high standards at all times
Clause 26.1 Requirement not to advertise prescription only medicines to the public
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

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