AUTH/3868/12/23: Rosemont Pharmaceuticals – LinkedIn post and alleged public access to POM webpage (No breach)

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Key facts

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Case number	AUTH/3868/12/23
Company	Rosemont Pharmaceuticals Ltd
Complainant	Anonymous, non-contactable (described as a health professional)
Complaint theme	Alleged promotion to the public (LinkedIn post and alleged public access to promotional website material)
Material(s)	LinkedIn post (9 November 2023); website product page relating to gabapentin
Applicable Code year	2021
Clauses considered	2, 5.1, 8.1, 26.1, 26.2
Outcome	No breach of the Code
Appeal	No appeal
Complaint received	15 December 2023
Case completed	13 December 2024

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

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An anonymous, non-contactable complainant (described as a health professional) alleged a patient saw Rosemont “advertising on LinkedIn”, then accessed “a large range of promotional material” on Rosemont’s website and requested certain medicines.
The complaint focused on a specific product webpage relating to gabapentin (an anticonvulsant), with an allegation that the webpage was not clearly approved/certified.
Rosemont stated the LinkedIn post (9 Nov 2023) was factual/general, named no product, and contained no link to the website or the gabapentin page.
Rosemont stated product-specific website content was behind an HCP self-certification “challenge wall”.
Rosemont provided evidence of certification for the relevant webpage (marketing approval certificate signed by a qualified medical practitioner) and described its internal approval system (including traceable digital approval implemented March 2023, ROS codes, and internal expiry dates prompting reapproval around two years).

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No breach of Clause 26.1 (LinkedIn post was corporate advertising and did not advertise a prescription only medicine to the public; no causal link to promotion of a POM).
No breach of Clause 26.2 (post could not be construed as encouraging the public to ask for a specific POM).
No breach of Clause 26.1 (website: Panel accepted evidence that HCP self-certification was required to access the relevant product pages; complainant did not establish public access).
No breach of Clause 8.1 (gabapentin webpage was certified appropriately).
No breach of Clause 5.1 (no additional evidence of failure to maintain high standards).
No breach of Clause 2 (in absence of other breaches, no discredit/reduced confidence in the industry).

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