AUTH/3920/6/24: Complainant v AstraZeneca — LinkedIn ‘Experience’ section references to Enhertu (no breach) | PMCPA Case

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Key facts

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Case number	AUTH/3920/6/24
Company	AstraZeneca
Complainant	Named, contactable complainant (described themselves as a physician)
Material/channel	LinkedIn profile (‘Experience’ section) of a senior AstraZeneca employee
Medicine referenced	Enhertu (trastuzumab deruxtecan)
Main allegations	Advertising a POM to the public; off-licence/future indication promotion; promotion prior to MA; inappropriate use of “new”; “blockbuster” raising hopes; lack of certification and prescribing information; high standards/Clause 2 concerns
Applicable Code	2021
Clauses considered	2, 3.1, 5.1, 6.5, 8.1, 12.1, 26.1, 26.2
Panel decision	No breach of all clauses listed
Complaint received	4 June 2024
Case completed	17 April 2025
Appeal	No appeal
Sanctions	None stated

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

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A named complainant (describing themselves as a physician) complained about content in the ‘Experience’ section of a senior AstraZeneca employee’s LinkedIn profile.
The complainant alleged the profile referenced Enhertu (trastuzumab deruxtecan) by brand name and mentioned trials/indications including HER2-low, amounting to off-licence promotion to the public and promotion of future indications.
The complainant also alleged the profile used the word “new” inappropriately (given Enhertu had been licensed/reimbursed in breast cancer since 2022) and described Enhertu as a “blockbuster”, potentially raising hopes and downplaying safety.
The complainant alleged the content was promotional and therefore lacked certification and prescribing information.
AstraZeneca argued the content sat within the LinkedIn ‘Experience’ section (akin to a CV), required multiple steps (searching, navigating, scrolling/clicking) to view, and was primarily directed at recruiters/potential employers rather than the general public.
The Panel reviewed specific phrases in the ‘Experience’ section including: “During my time on ENHERTU”; “…delivery of the multi-award winning DB-03 and DB-04 launch phase.”; “I directly influence CDP development in HER2-Low and launch readiness for new HER2+ blockbuster indications.”

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No breach of Clause 26.1 (not advertising a prescription only medicine to the public).
No breach of Clause 3.1 (no promotion prior to marketing authorisation; Enhertu was licensed in the UK at the time of complaint).
No breach of Clause 5.1 (x2) (high standards).
No breach of Clause 26.2 (public information must be factual/balanced and not raise unfounded hopes).
No breach of Clause 6.5 (use of “new” was not describing a specific product/presentation/indication as new; it referred to potential new indications in development in the context of the individual’s role).
No breach of Clause 12.1 (prescribing information not required because the Panel did not consider the content promotional to health professionals).
No breach of Clause 8.1 (certification not required on the same basis).
No breach of Clause 2 (no discredit/reduced confidence found, given no other breaches).

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