AUTH/3865/12/23: Ex-employee v Novo Nordisk (Wegovy promotional meeting)

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Key facts

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Case number	AUTH/3865/12/23
Complainant	Named, contactable ex-employee
Company	Novo Nordisk
Product	Wegovy
Activity type	Promotional meeting
Meeting location/dates	Scotland, 04–05 November 2022
Main allegation	Promotion to NI health professionals when Wegovy allegedly lacked MA in NI at the time
Applicable Code year	2021
Panel ruling	No breach of Clauses 2, 3.1, 5.1, 5.6, 24.2
Clauses raised but not ruled on	15.5, 26.1, 26.2 (related to third-party email allegation not referred to Panel)
Complaint received	16 December 2023
Case completed	23 August 2024
Appeal	No appeal

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

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An ex-employee complained about a Novo Nordisk promotional meeting for Wegovy held in Scotland on 04–05 November 2022.
The complainant alleged Wegovy did not have a marketing authorisation (MA) in Northern Ireland (NI) at that time and was being promoted to a speaker and other health professionals from NI.
The complainant also referenced receiving an email from a third party promoting Wegovy; the case preparation manager determined there was no prima facie case on that email allegation and it was not referred to the Panel.
Novo Nordisk stated Wegovy had MA in NI (EMA, 22 January 2022) and in Great Britain (MHRA, 10 May 2022) before the meeting.
Novo Nordisk provided the meeting agenda, certified slide decks, a speaker agreement/briefing, and a delegate list; it said all seven delegates worked in specialist weight management services and had a primary place of practice within Scotland.

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No breach of Clause 2.
No breach of Clause 3.1.
No breach of Clause 5.1.
No breach of Clause 5.6.
No breach of Clause 24.2.
No ruling made in relation to Clauses 15.5, 26.1 and 26.2 (these were raised only in relation to the third-party email matter that was not referred to the Panel).

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Clause 2 – Requirement that activities or materials must not bring discredit upon, or reduce confidence in, the pharmaceutical industry
Clause 3.1 – Requirement that a medicine must not be promoted prior to the grant of its marketing authorisation
Clause 5.1 – Requirement to maintain high standards at all times
Clause 5.6 – Requirement that material should only be provided or made available to those groups of people whose need for or interest in it can be reasonably assumed
Clause 24.2 – Requirement that arrangements which cover genuine consultancy or other services fulfil the criteria listed in this clause

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