GSK breach for patient organisation articles: funding acknowledgement not clear from the outset (AUTH/3895/5/24)

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Key facts

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Case	AUTH/3895/5/24
Parties	Complainant v GSK
Issue	Declarations of involvement on patient organisation website articles
Materials	Four patient-facing Q&A articles on a patient organisation website
Funding type (as found/accepted)	Grant (arm’s length)
Disclosure wording (as shown)	“This patient information resource has been made possible with a financial contribution from GSK. GSK has had no editorial input into or control over the content which has been independently owned and created by [patient organisation].”
Key failing	Disclosure was at the bottom of each page and not in the first field of vision; not acknowledged from the outset
Applicable Code year	2021
Breach clauses	Clause 25.3
No breach clauses	Clauses 2, 5.1, 8.3
Complaint received	04 May 2024
Case completed	30 June 2025
Appeal	No appeal
Sanctions	Undertaking received; additional sanctions not stated

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

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An anonymous complainant challenged four patient-facing Q&A articles on a patient organisation website that were funded by GSK via a grant.
The funding statement appeared only at the bottom of each article, meaning a reader had to scroll to see it.
The complainant alleged the declaration was unclear (grant vs sponsorship) and that the material should have been certified as disease awareness material if it was sponsorship.
GSK said it was an arm’s length grant, with no editorial input, and that a certified written agreement required prominent acknowledgement of GSK funding.
The Panel accepted the arrangement was an arm’s length grant, but considered Clause 25.3 could still apply given the broad definition of sponsorship and the Code’s transparency intent.

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Breach: Clause 25.3 (failing to ensure sponsorship is clearly acknowledged from the outset).
No breach: Clause 8.3 (requirement to certify non-promotional material) – did not apply on the basis funding was a grant.
No breach: Clause 5.1 (high standards).
No breach: Clause 2 (discredit to the industry).

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