AUTH/3812/8/23: Proveca – Google search results for Sialanar and alleged public advertising (No breach)

📊

Key facts

⌄

Case number	AUTH/3812/8/23
Company	Proveca
Product	Sialanar (glycopyrronium)
Issue	Google search results allegedly amounted to public advertising/promotional material; adequacy of public information on company website
Complainant	Anonymous, contactable complainant (member of the public)
Complaint received	16 August 2023
Case completed	25 November 2024
Applicable Code	2021
Panel outcome	No breach
Clauses considered in outcome	Clause 5.1 (x2), Clause 16.1, Clause 26.1
Appeal	No appeal

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

📋

⌄

An anonymous, contactable complainant (a member of the public) said Google searches for “Sialanar” and “glycopyrronium” surfaced Proveca links that felt like promotion to the public.
The complainant said they were forced to self-identify as a healthcare professional (HCP) to access Sialanar information and that there was no patient/public link.
Proveca said it had discontinued SEO in May 2023 and that Google results were due to automatic indexing/algorithms.
Proveca stated product pages were promotional and appropriately restricted behind an HCP self-declaration gate; non-HCPs were redirected to the homepage with company/therapy-area information and contact/medical information details.
The Panel assessed: (1) alleged SEO/public promotion, (2) adequacy of public information on the website, (3) whether this was “promotional material” under Clause 16.1, and (4) high standards.

⚖️

⌄

No breach of Clause 26.1 (Requirement not to advertise prescription only medicines to the public).
No breach of Clause 5.1 (x2) (Requirement to maintain high standards at all times).
No breach of Clause 16.1 (Requirement that promotional material about prescription only medicines directed to a UK audience which is provided on the internet must comply with all relevant requirements of the Code).
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