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PMCPA Case

Novo Nordisk: sponsorship of pharmacy weight-loss services, free consumables and missing Disclosure UK entry (Saxenda) | AUTH/3821/9/23

📅 2023 | 🖉 Dr Anzal Qurbain
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Key facts

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CaseAUTH/3821/9/23
ComplainantAnonymous and non-contactable complainant (described themselves as a health professional)
CompanyNovo Nordisk Ltd
Medicine(s)Saxenda (liraglutide 3mg); Wegovy referenced in allegations
Main issuesSponsorship of pharmacy-chain weight management services; arm’s-length concerns; free consumables viewed as inducement; Disclosure UK ToV omission; alleged public promotion via ads and US websites; supply-shortage context
Applicable Code year2021 (with one contract assessed under 2019 Code)
Complaint received6 September 2023
Case completed12 August 2024
AppealNo appeal
Breach clauses2019: Clause 2; Clause 9.1. 2021: Clause 2; Clause 5.1 (x2); Clause 28.1.
No breach clausesClause 3.4; Clause 5.1 (x4); Clause 26.1 (x2); Clause 26.2; Clause 28.1 (x2)
SanctionsUndertaking received; Additional sanctions: Advertisement
Notable Panel observationsArrangements not strictly arm’s length; detailed reporting and company involvement compromised arm’s length; free needles defrayed unavoidable cost and were an inducement; transparency and sponsorship declarations should be addressed across all sponsored materials/activities; poor understanding of the Code contributed to Clause 2 concerns

Download the full case report (PDF)

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

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What happened

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  • An anonymous health professional complained about Saxenda (liraglutide 3mg) in the context of GLP-1 supply shortages and alleged Novo Nordisk continued to promote Saxenda despite supply issues.
  • The complainant alleged Novo Nordisk sponsored large national pharmacy chains with online prescribing to support private weight management services, and that this sponsorship was promotional/created commercial incentive.
  • The complainant alleged Novo Nordisk supplied “free stock” to pharmacy chains; Novo Nordisk denied providing medicines free of charge and said any discounts were separate commercial arrangements.
  • The complainant alleged sponsorship funding was used to promote prescription-only medicines to the public (eg via Google ads/search results naming Saxenda/Wegovy).
  • The complainant alleged transfers of value (ToVs) were not declared on Disclosure UK.
  • The complainant alleged Novo Nordisk promoted to the UK public via US websites (saxenda.com and wegovy.com).
  • Panel review focused on sponsorship contracts with three pharmacy chains (A, B, C). Novo Nordisk said it had no sponsorship/support for a fourth alleged chain (D).
  • The Panel found the sponsorships were not strictly arm’s length, partly due to detailed reporting requirements (including data such as website traffic, conversion, number of patients starting Saxenda, repeat prescriptions, duration of treatment, geography, number of pens prescribed) and Novo Nordisk’s ongoing role in some activities (eg medical training sessions).
  • Two sponsorships included provision of consumables free of charge (eg needles essential for Saxenda administration; also sharps bins and travel wallets). The Panel considered this defrayed unavoidable costs associated with prescribing Novo Nordisk’s injectable weight-loss medicine(s) and, on balance, amounted to an inducement.
  • Novo Nordisk admitted an “inadvertent oversight” meant Pharmacy Chain A was not tagged as a healthcare organisation in its finance system, so the 2022 sponsorship ToV was not disclosed (it said it was being re-submitted for inclusion in the 2022 Disclosure UK portal).
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Outcome

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  • 2019 Code: Breach of Clause 2; Breach of Clause 9.1.
  • 2021 Code: Breach of Clause 2; Breach of Clause 5.1 (x2); Breach of Clause 28.1.
  • No breach findings were made for: Clause 3.4; Clause 5.1 (x4); Clause 26.1 (x2); Clause 26.2; Clause 28.1 (x2).
  • The Panel ruled no breach regarding alleged promotion during supply issues (complainant did not establish that promotional activity meant high standards were not maintained).
  • The Panel ruled no breach regarding “free stock” of medicines (no evidence medicines were provided free of charge).
  • The Panel ruled no breach of Clauses 26.1/26.2 (complainant did not establish Novo Nordisk funded/was responsible for the pharmacy search results; and US websites were not established to be within scope under Clause 1.2).
  • The Panel ruled a breach of Clause 28.1 for failure to disclose ToVs to Pharmacy Chain A (a healthcare organisation under Clause 1.8 due to its online doctor/weight loss service).
  • The Panel ruled Clause 2 breaches due to serious concerns, heightened public sensitivity around weight-loss medicines, inducement findings, and transparency failures; it also criticised Novo Nordisk’s understanding of what “arm’s length” requires.
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