GSK breach upheld on taskforce website: sponsorship not clearly acknowledged “from the outset” (Clause 25.3)

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Key facts

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Case number	AUTH/3845/11/23 (CASE/3845/11/23)
Respondent	GSK UK Limited
Complainant	Anonymous, contactable complainant
Issue	Disclosure of sponsorship/funding on a taskforce website and related materials; whether acknowledgement was clear “from the outset”.
Context	Grant funding to a patient organisation to support a therapy-area taskforce; multiple funders; GSK contribution stated as ~10% of total required.
Applicable Code	2021
Breach	Clause 25.3
No breach	Clauses 2, 5.1, 27.2
Appeal	Yes (GSK appealed Clause 25.3); unsuccessful; breach upheld.
Sanctions	Undertaking received; additional sanctions not stated.
Complaint received	2 November 2023
Case completed	13 March 2025

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

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An anonymous complainant alleged GSK funded a patient organisation to support a therapy-area taskforce, but the taskforce website and related materials did not clearly declare GSK’s support “from the outset”.
GSK said the funding was an unsolicited grant (about 10% of total), provided at arm’s length with no editorial control, and that the grant agreement required the patient organisation to acknowledge GSK funding prominently.
The Panel reviewed screenshots of the website (including an “About” page listing multiple company funders and stating they had no editorial rights) and considered whether visitors would see funding information at the start of their journey.
GSK appealed the Clause 25.3 breach, arguing a “Funding Acknowledgement” link existed on every page (in the footer) and had always been present.
The Appeal Board found the footer “Funding acknowledgement” link (small font, bottom left) was not sufficient to be “from the outset” because users could navigate without noticing it.

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Clause 25.3 – Breach: Failing to ensure that all sponsorship is clearly acknowledged from the outset and that the wording of the declaration of sponsorship is unambiguous and accurately reflects the extent of the company’s involvement and influence over the material.
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 27.2 – No breach: Requirement for a written agreement when providing donations, grants or sponsorship to patient organisations.

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