Gilead: Conference Wi‑Fi landing page linked to US corporate site press release promoting investigational lenacapavir use (AUTH/3848/11/23)

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Key facts

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Case number	AUTH/3848/11/23
Parties	Complainant v Gilead
Company(ies)	Gilead Sciences Ltd (ABPI member); activity involved Gilead Sciences Europe Ltd (UK-based affiliate); website owned/managed by Gilead Sciences Inc (US)
Issue	Conference Wi‑Fi default homepage directed delegates to US corporate site featuring press release about investigational lenacapavir use for HIV prevention (PrEP)
Location/context	European HIV conference in Poland (2023); mixed audience likely including health professionals and members of the public
Medicine	Lenacapavir
Alleged conduct	Promotion of investigational/unlicensed indication via Wi‑Fi landing page; exposure of public/community attendees
Applicable Code	2021
Clauses considered	2, 5.1, 11.2, 26.1
Breaches	Clause 5.1; Clause 11.2; Clause 26.1
No breach	Clause 2
Sanctions	Undertaking received; additional sanctions not stated
Complaint received	7 November 2023
Case completed	6 March 2025
Appeal	No appeal

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

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At a European HIV conference (Poland, 2023), Gilead Sciences Europe Ltd sponsored delegate Wi‑Fi as part of a sponsorship package where “the sponsor’s website will be the default homepage”.
Delegates accessed Wi‑Fi using a password that included “Gilead” and were directed to the US-owned Gilead global corporate homepage.
The homepage contained a “Recent News” item linking to a press release: “Gilead Sciences Announces New Clinical Trial in Europe to Assess Lenacapavir for HIV Prevention as Part of Landmark Purpose Program”.
The linked press release included language about PrEP needs and potential benefits (e.g., “critical need to bring forward new PrEP options”, “innovations that can help end the HIV epidemic in Europe”) and referenced a trial in the UK.
A pop-up stated: “Welcome. Some content on this site is not intended for people outside the United States.” The Panel considered the intended audience was not made unambiguously clear on the homepage.
The complainant (anonymous UK health professional) alleged forced exposure of HCPs and members of the public (including community attendees) to promotional content for an investigational/unlicensed indication (HIV prevention/PrEP).

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Breach of Clause 5.1 (Failing to maintain high standards).
Breach of Clause 11.2 (Promoting a medicine for an unlicensed indication).
Breach of Clause 26.1 (Advertising a prescription only medicine to the public).
No breach of Clause 2 (Requirement that activities or materials must not bring discredit upon, or reduce confidence in, the pharmaceutical industry).

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