AUTH/3826/09/23: Ex-contractor v GSK — allegations of falsified/duplicated rep calls in CRM (No breach)

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Key facts

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Case number	AUTH/3826/09/23
Parties	Ex-contractor v GSK
Allegation summary	Representatives allegedly falsified/duplicated calls in CRM; implied concern about frequency/number of calls to HCPs and potential inconvenience; alleged management awareness and financial reward linked to call rate.
Applicable Code	2021
Complaint received	18 September 2023
Case completed	24 March 2025
Scope decision	CRM-recording aspect outside scope; frequency/number of calls aspect within scope (per independent referee).
Clauses considered	Clauses 2, 5.1, 17.2, 17.4
Outcome	No breach of Clauses 2, 5.1, 17.2, 17.4
Sanctions	None stated

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

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An ex-contractor alleged GSK hospital representatives were falsifying and duplicating calls in GSK’s CRM system, and that management were aware despite being shown evidence.
The complainant alleged the representatives (and manager) were receiving financial reward linked to “false call rate”.
GSK said the issue related to internal operational/HR matters and was largely outside the Code’s scope; it conducted an internal review and said it found no evidence of unethical conduct or falsification.
GSK said some “double entries” were explainable due to guidance on logging multiple interactions with the same HCP on the same day (eg 1:1 plus group meeting), and that there were no financial incentives linked to call rate for the team at the relevant time.
The Panel initially ruled the matter outside the scope of the Code and therefore no breach.
The complainant appealed; an independent referee concluded one aspect was in scope: the implied allegation about the number/frequency of calls to HCPs (Clause 17.4).
The Panel reconvened to consider only the implied allegation about frequency/number of calls and potential inconvenience to HCPs.

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No breach of Clause 17.4.
No breach of Clause 17.2.
No breach of Clause 5.1.
No breach of Clause 2.
Panel conclusion on reconvened issue: the complainant did not demonstrate (on the balance of probabilities) that CRM records reflected actual calls/interactions, nor that any interactions caused inconvenience considering frequency, timing, and wishes of individuals.

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Clause 2 Requirement that activities or materials must not bring discredit upon, or reduce confidence in, the pharmaceutical industry
Clause 5.1 Requirement to maintain high standards at all times
Clause 17.2 Requirement that representatives must maintain high standards of ethical conduct in the discharge of their duties and comply with all relevant requirements of the Code
Clause 17.4 Requirement that representatives must ensure that the frequence, timing and duration of calls, together with the manner in which they are made does not cause inconvenience and that the wishes of individuals on whom representatives call and the arrangements in force at any particular establishment must be observed

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