AUTH/3823/9/23: GSK LinkedIn ‘likes’ on US momelotinib approval posts – no breach (Clauses 12.1, 12.10, 26.1)

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Key facts

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Case number	AUTH/3823/9/23
Company	GSK
Complaint	Alleged promotion to the public and missing obligatory information from promotional posts on LinkedIn (“No PI or black triangle”).
Channel	LinkedIn (GSK corporate post and an employee post), linking to a GSK.com press release.
Medicine	Momelotinib (Ojjaara)
UK authorisation status at the time	Not authorised in the UK (no UK marketing authorisation).
Key issue considered	Whether ‘likes’/engagement constituted promotion to the public and required PI/black triangle under Clauses 12.1/12.10, and whether Clause 26.1 applied.
Applicable Code	2021
Clauses considered	12.1, 12.10, 26.1
Panel decision	No breach of Clauses 12.1, 12.10, 26.1
Complaint received	18 September 2023
Case completed	20 November 2024
Appeal	No appeal

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

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An anonymous, non-contactable complainant alleged LinkedIn activity by GSK staff amounted to promotion to the public and lacked obligatory information (“No PI or black triangle”).
The LinkedIn activity related to posts about FDA approval in the USA of momelotinib (Ojjaara) for myelofibrosis patients with anaemia.
One post was from the GSK corporate LinkedIn account, linking to a press release on GSK.com labelled “For media and investors only”.
A second post was made by a Switzerland-based GSK employee about the approval, also linking to the same press release.
UK-based GSK employees ‘liked’ the posts; GSK accepted this brought the posts within the scope of the ABPI Code.
GSK contacted the UK employees and the ‘likes’ were removed (two on 18 September 2023; the third on 19 September 2023) and issued an internal reminder/briefing to the UK affiliate Oncology team (97 members) on appropriate social media engagement.

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No breach of Clause 12.1 (Requirement to include up-to-date prescribing information).
No breach of Clause 12.10 (Requirement to include the black triangle in promotional material).
No breach of Clause 26.1 (Requirement not to advertise prescription only medicines to the public).
No appeal.

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