Roche breached Clause 25.3 after BBC radio programme lacked clear sponsorship declaration from the outset (AUTH/3897/5/24)

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Key facts

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Case number	AUTH/3897/5/24
Company	Roche
Complainant	Anonymous, non-contactable
Complaint theme	Failure to declare Roche sponsorship in an online/BBC radio programme; alleged need to certify as disease awareness
Channel	BBC radio/audio programme (online listen/download) linked to a campaign event
Therapy area mentioned	Age-related macular degeneration (AMD)
Applicable Code year	2021
Breach findings	Clause 25.3
No breach findings	Clauses 2, 5.1, 8.3
Panel reasoning highlight	Third-party facilitated interviews; Roche responsible for acts/omissions (Clause 1.24 referenced); no briefing for interviews meant sponsorship not acknowledged from the outset
Sanctions	Undertaking received; additional sanctions not stated
Complaint received	06 May 2024
Case completed	08 July 2025
Appeal	No appeal

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

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An anonymous complainant alleged that a BBC radio/audio programme about a campaign sponsored by Roche featured interviews with campaign partners but did not declare Roche’s involvement from the outset.
The complainant also alleged the programme discussed age-related macular degeneration (AMD), so it was disease awareness heard by the public and should have been certified.
Roche said the BBC programme was independently produced and that all campaign/event materials it provided were certified and clearly stated: the campaign was a partnership including Roche and that Roche funded the partnership’s activities.
The Panel noted a third-party communications company (acting as secretariat support) invited the BBC and offered to facilitate interviews with partnership representatives.
The transcript of the broadcast contained no declaration of Roche or its involvement during the interviews; the webpage listing partners named Roche but did not explain its involvement.
Roche confirmed it provided no briefing to the communications company (or others) in relation to the BBC interviews.

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Breach of Clause 25.3 (Failing to ensure sponsorship is clearly acknowledged from the outset).
No breach of Clause 8.3 (Requirement to certify non-promotional material) because the programme was produced and issued independently by the BBC, so Clause 8.3 was not applicable.
No breach of Clause 5.1 (Requirement to maintain high standards at all times).
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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