Jazz Pharmaceuticals UK: Patient organisation materials lacked clear funding disclosure from the outset (AUTH/3921/06/24)

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Key facts

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Case number	AUTH/3921/06/24
Parties	Complainant v Jazz Pharmaceuticals UK
Complaint theme	Disclosure of company involvement (patient organisation webpage and patient information booklets)
Applicable Code year	2021
Complaint received	07 June 2024
Case completed	09 July 2025
Appeal	No appeal
Materials at issue	Patient organisation health information webpage; three patient information booklets (downloadable/printable)
Funding described	Unrestricted grant of £10,000 (~5% of total project cost) for transformation of health information portfolio
Breach clauses	Clause 5.1; Clause 23.2 (x4); Clause 25.3 (x4)
No breach clauses	Clause 2; Clause 5.1 (webpage aspect)
Sanctions	Undertaking received; Additional sanctions: Not stated

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

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An anonymous health professional complained that a patient organisation’s health information webpage did not make Jazz Pharmaceuticals’ involvement clear from the outset, with disclosure only appearing at the end of a long scrolling page.
The complainant also alleged three patient information booklets did not include any declaration of Jazz’s involvement.
Jazz said it provided an unrestricted grant (£10,000; ~5% of total project cost) to support transformation of the patient organisation’s health information portfolio, and argued this was a grant (not sponsorship) and that it did not fund the specific booklets.
The Panel considered the funding could be both a grant and sponsorship, and that transparency requirements applied to the webpage and the booklets, which needed to “stand alone”.
The grant agreement required Jazz to be “prominently mentioned as a sponsor” on publications, but gave no detail on wording/positioning.

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Breach of Clause 23.2 (x4) – failing to ensure company involvement was made clear for donations and grants to the extent possible (webpage + 3 booklets).
Breach of Clause 25.3 (x4) – failing to ensure all sponsorship is clearly acknowledged from the outset (webpage + 3 booklets).
Breach of Clause 5.1 – failing to maintain high standards (in relation to the booklets).
No breach of Clause 2 – Panel did not consider the circumstances warranted Clause 2 censure.
No breach of Clause 5.1 – in relation to the webpage (because disclosure was present, though inadequate for Clauses 23.2/25.3).

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