GSK breach for unclear sponsorship disclosure on third-party conference webpages (AUTH/3915/5/24)

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Key facts

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Case number	AUTH/3915/5/24
Company	GSK (GlaxoSmithKline UK Limited)
Complainant	Health professional (later became non-contactable)
Issue	Alleged lack of clear sponsorship declaration from the start of a conference programme overview webpage and an agenda PDF
Materials	Two third-party materials on a healthcare organisation’s website: programme overview webpage and agenda PDF
Applicable Code year	2021
Breach findings	Clause 25.3 (x2)
No breach findings	Clause 2; Clause 5.1
Sanctions	Undertaking received
Complaint received	31 May 2024
Case completed	18 September 2025
Appeal	No appeal

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

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A health professional complained that a healthcare organisation’s conference was sponsored by GSK but this was not clearly declared from the start of: (1) a conference programme overview webpage and (2) a conference agenda (PDF) accessible online.
GSK was one of five sponsors and had a sponsorship contract (signed 13 March 2024) that included entitlements such as a 30-minute sponsored symposium and a large exhibition stand.
On the programme overview webpage, GSK’s logo appeared in a “Partner organisations” ribbon near the bottom of the page, linking to a “Partners” page with logos and brief company profiles.
On the agenda PDF, GSK’s symposium was labelled “Sponsored symposium – GSK”, but the broader sponsorship declaration (about sponsors/exhibitors funding event costs and having no editorial input) appeared only at the end of the three-page document in smaller bold/italic text with a hyperlink to an Exhibitors page.
The Panel considered readers could interact with the programme overview content and navigate away without reaching the sponsor logos at the bottom, and that the “Partner organisations” presentation did not explain what the partnership related to (organisation vs conference).
The Panel applied the principle that materials must be capable of standing alone for Code compliance; the agenda PDF could be found via search and therefore needed an “from the outset” sponsorship declaration within the document itself.

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Breach of Clause 25.3 (x2) for failing to ensure sponsorship was clearly acknowledged from the outset (programme overview webpage and agenda PDF).
No breach of Clause 5.1 (high standards) because, despite the Clause 25.3 issues, there were indicators of involvement (logo ribbon; symposium labelled; end-of-document declaration with hyperlink) and the Panel considered the Clause 25.3 rulings adequately covered the matter.
No breach of Clause 2 (discredit) as the circumstances did not warrant the particular censure of Clause 2.
No appeal.

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Clause 25.3 (Breach x2) – Failing to ensure sponsorship is clearly acknowledged from the outset.
Clause 5.1 (No breach) – Requirement to maintain high standards at all times.
Clause 2 (No breach) – Requirement that activities or materials must not bring discredit upon, or reduce confidence in, the pharmaceutical industry.

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