Boehringer Ingelheim: Jardiance slide deck left accessible beyond recertification and PI link failed (AUTH/3906/5/24)

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Key facts

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Case number	AUTH/3906/5/24
Company	Boehringer Ingelheim Limited
Product	Jardiance (empagliflozin)
Material	Case study presentation slide deck: “Weight and type 2 diabetes”
Channel	Boehringer promotional website / CMS-hosted asset accessible via URL
Audience	Primary care health professionals
Main issues	Recertification beyond 2 years; PI not accessible via direct single click; reviewer comments visible; alleged lack of context for comparative table (not upheld)
Applicable Code year	2021
Breach clauses	Clause 5.1 (x2), Clause 8.5, Clause 12.1, Clause 12.4
No breach clauses	Clause 2, Clause 6.1, Clause 6.2, Clause 8.1
Complaint received	16 May 2024
Case completed	6 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 found a Jardiance (empagliflozin) case-study slide deck (“Weight and type 2 diabetes”) accessible via a URL on a Boehringer promotional website.
The deck appeared to have been prepared/certified in January 2021 and, in the complainant’s view, had not been updated/recertified within the required 2-year period.
The deck contained visible reviewer comments (eg, “note to reviewers”), suggesting a draft or non-final version was accessible.
The prescribing information (PI) was not included in the deck and the PI hyperlink was not a direct, single-click route when accessed by the complainant.
The complainant also challenged a slide/table about the impact of diabetes medicines on weight as lacking sufficient context (study design/endpoints) to interpret meaningfully.
Boehringer said the deck was certified 27 Jan 2021 and intended to be retired 1 July 2021; due to human error and technical issues it was not manually withdrawn from the CMS and the URL was not deactivated when the webpage was decommissioned, leaving it accessible until 21 May 2024.
Boehringer said the PI link worked until July 2022, but later PI housing changes meant the link no longer worked when the complainant accessed it.

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Breach of Clause 5.1 (x2) Failing to maintain high standards.
Breach of Clause 8.5 Using material for more than two years without re-certification.
Breach of Clause 12.1 Failing to include up-to-date prescribing information.
Breach of Clause 12.4 Failing to include prescribing information within the digital material or via a direct, single click link.
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 6.1 Requirement that information must be accurate, up-to-date and not misleading.
No breach of Clause 6.2 Requirement that information must be capable of substantiation.
No breach of Clause 8.1 Requirement to certify promotional material.

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