GSK COPD decision support tool: sponsorship declaration not shown from the outset (Clause 25.3)

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Key facts

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Case	AUTH/3898/5/24
Company	GSK
Issue	Declaration of involvement in an online COPD decision support tool; sponsorship not clearly acknowledged from the outset of the homepage at time of complaint
Tool	Online COPD Decision Support Tool (for UK healthcare professionals)
Applicable Code year	2021
Complaint received	08 May 2024
Case completed	08 August 2025
Appeal	No appeal
Breach	Clause 25.3
No breach	Clauses 2, 5.1, 8.1, 8.3, and Clause 25.3 (re declarations on all tool-generated materials/outputs)
Sanctions	Undertaking received; Additional sanctions: Not stated
Panel’s key reasoning	GSK did not ensure the updated declaration appeared at the outset after sponsorship expiry (eg, by verifying it had been updated/positioned so users would see it without scrolling)

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

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An anonymous complainant alleged an online COPD decision support tool sponsored by GSK did not declare GSK’s involvement from the outset of the tool’s homepage; the declaration appeared only at the end of the page.
The complainant also alleged that materials relating to the tool (including prompts, alerts, notes and outputs) should have carried declarations and should have been certified.
GSK explained the tool was developed/hosted by a third-party organisation (a UK university spin-out) under a sponsorship agreement (dated 28 November 2019) covering development and hosting.
During the sponsorship period, the homepage displayed the GSK declaration twice (near the top and near the bottom). Sponsorship ended on 13 April 2023; the declaration wording was updated to reflect the end date.
At the time of the complaint (May 2024), the top-of-page declaration had been removed (only the lower declaration remained). GSK asked the third party to reinstate it; this was confirmed within four days.

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Breach of Clause 25.3 – failing to ensure sponsorship is clearly acknowledged from the outset.
No breach of Clause 2 – requirement that activities or materials must not bring discredit upon, or reduce confidence in, the pharmaceutical industry.
No breach of Clause 5.1 – requirement to maintain high standards at all times.
No breach of Clause 8.1 – requirement to certify promotional material.
No breach of Clause 8.3 – requirement to certify non-promotional material.
No breach of Clause 25.3 – in relation to whether declarations were required on all materials/outputs generated by the tool (prompts/alerts/outputs).

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