AstraZeneca found in breach over HCP tweet lacking disclosure of company involvement in Speak Up for COPD campaign (AUTH/3837/10/23)

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Key facts

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Case number	AUTH/3837/10/23
Company	AstraZeneca
Complaint	Alleged lack of transparency about AstraZeneca involvement in a Twitter post and on the Speak Up for COPD website
Channel	Twitter (X) post; campaign website
Material/date	Twitter post dated 14 November 2022 (complaint received 11 October 2023)
Applicable Code	2021
Breach findings	Clause 5.5 (Twitter post)
No breach findings	Clause 2; Clause 5.1; Clause 5.5 (website); Clause 24.2
Panel rationale (headline)	HCP was considered a third party under Clause 1.24 due to contracted steering committee role; post should have declared association with AstraZeneca
Sanctions	Undertaking received; additional sanctions not stated
Complaint received	11 October 2023
Case completed	22 January 2025
Appeal	No appeal

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

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An anonymous complainant challenged a Twitter (X) post (14 November 2022) by a respiratory health professional referencing “#speakupforCOPD” and showing “speakupforcopd.com”.
The complainant alleged the post did not mention AstraZeneca despite AstraZeneca funding the Speak Up for COPD campaign.
The complainant also alleged AstraZeneca’s involvement was not clear “from the outset” on the Speak Up for COPD website.
AstraZeneca said the HCP was not paid or contracted to post about the campaign; they were contracted (but not paid) to participate in AstraZeneca’s COPD Global Respiratory Policy Steering Committee.
AstraZeneca had provided committee members with a toolkit of certified campaign assets for World COPD Day, but the HCP’s post was not taken from that approved content.
The Panel focused on whether the HCP was a “third party” for whom AstraZeneca was responsible under the Code (Clause 1.24, referenced by the Panel).

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Breach of Clause 5.5 in relation to the Twitter post: failing to be sufficiently clear as to the company’s role and involvement.
No breach of Clause 5.5 in relation to the Speak Up for COPD website: the homepage was considered unambiguous and sufficiently prominent about AstraZeneca support/funding.
No breach of Clause 5.1 (high standards).
No breach of Clause 2 (discredit/reduce confidence in the industry).
No breach of Clause 24.2 (contracted services criteria) because there was no clear allegation about the written agreement’s content.

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Clause 5.5 (Breach) – Failing to be sufficiently clear as to the company’s role and involvement.
Clause 2 (No breach) – Requirement that activities or materials must not bring discredit upon, or reduce confidence in, the pharmaceutical industry.
Clause 5.1 (No breach) – Requirement to maintain high standards at all times.
Clause 5.5 (No breach) – Requirement to be sufficiently clear as to the company’s role and involvement (website).
Clause 24.2 (No breach) – Requirement that arrangements for contracted services fulfil specific criteria.

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