Completed cases

Complaints considered by the Code of Practice Panel are judged on the evidence provided by both parties. Once concluded a case report is published on this website. Good compliance decisions rely on both the interpretation of the Code and an understanding of its application, published case reports help in this regard and set precedent in a particular set of circumstances. When making decisions on compliance with the Code, knowledge gained from previous case reports can be beneficial.                        

Search options for completed cases can be found below, please scroll down.

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Please Note:

Cases can only link to clauses in the interactive 2019 or 2016 Codes.




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An anonymous, non-contactable UCB employee complained about the openly accessible LinkedIn profile of one of his/her colleagues in which the colleague described his/her role at UCB as ‘Supporting Phase 3 programme in axial spondyloarthropathy for bimekizumab’. The complainant explained that bimekizumab was currently at a late stage of clinical development and he/she expected that UCB would appreciate any pre-licence interest which could be drummed up before the marketing authorization was granted. The complainant submitted that the colleague’s...

Breach Clause(s): 3.1, 14.1, 9.1

No breach Clause(s): 2, 4.1, 4.9, 4.10, 26.1, 26.2

Applicable Code: 2019

Received: 13 December 2019

Completed: 27 March 2020

An anonymous, non-contactable individual, who described him/herself as a ‘concerned UK health professional’, drew attention to the webpages for IV irons on Vifor Pharma UK Limited’s corporate website and complained that the inverted equilateral triangle symbols were variously blue, grey or white and not black. The complainant was unclear as to whether the website was intended for the public or for health professionals as it included links to download leaflets for either patients or clinicians about...

Breach Clause(s): 4.10, 28.1

Applicable Code: 2019

Received: 12 August 2019

Completed: 26 March 2020

The owner and medical director of an aesthetics clinic, complained about the promotion of Botox (botulinum toxin type A) on social media by Allergan Limited. Botox was indicated for, inter alia, the temporary improvement in the appearance of facial lines at or above eye level when the severity of those lines had an important psychological impact in adults. The complainant alleged that Allergan had persistently de-medicalised the aesthetics industry and promoted prescription only medicines to the...

Breach Clause(s): 2, 9.1, 26.1

Applicable Code: 2019

Received: 17 December 2019

Completed: 16 March 2020

An anonymous, contactable individual, who described him/herself as a GP was concerned about claims allegedly made by Novo Nordisk representatives with regard to Ozempic (semaglutide) and weight loss and cardiovascular benefits which he/she alleged was off-label promotion. Ozempic was indicated for the treatment of certain adults with insufficiently controlled type 2 diabetes mellitus as an adjunct to diet and exercise. It was a once weekly GLP-1 RA (glucagon-like peptide-1 receptor agonist). The complainant was concerned that Novo...

Breach Clause(s): 7.2, 9.1

No breach Clause(s): 2, 3.2, 7.2, 7.3, 7.4, 7.10, 8.1, 9.1, 15.2, 15.9

Applicable Code: 2019

Received: 23 September 2019

Completed: 11 March 2020

A senior pharmacist at a clinical commissioning group (CCG), complained about the conduct of a representative at a meeting which took place in a GP practice to promote Eliquis (apixaban) which was co-promoted by Bristol-Myers Squibb Pharmaceuticals Ltd and Pfizer Ltd (the Alliance). Eliquis was on the CCG formulary albeit that GPs were being asked to change eligible patients from Eliquis to Lixiana (edoxaban, Daiichi Sankyo UK Limited). Eliquis and Lixiana were both anticoagulants indicated similarly,...

Breach Clause(s): 2, 7.2, 8.1, 15.2

No breach Clause(s): 7.3, 9.1

Applicable Code: 2019

Received: 13 November 2019

Completed: 09 March 2020

Colonis Pharma Limited voluntarily admitted that it had included the wrong prescribing information in a promotional letter (ref UK-CPL-121-008) about Melatonin 1mg/ml Oral Solution which was indicated for the short-term treatment of jet-lag in adults. As Paragraph 5.5 of the Constitution and Procedure required the Director to treat a voluntary admission as a complaint, the matter was taken up with Colonis. The detailed response from Colonis is given below. The Panel noted that the letter in question promoted...

Breach Clause(s): 2, 4.1, 9.1

Applicable Code: 2019

Received: 15 August 2019

Completed: 26 February 2020

A complainant who described him/herself as a ‘concerned UK health professional’, noted that one webpage on Diurnal Limited’s corporate website, in the section aimed at health professionals, referred to current products and those in the company’s pipeline. A downloaded copy of the page which showed a table of data headed ‘Diurnal’s drug-development pipeline – Europe’ was provided. The complainant alleged that the table constituted pre-licence promotion and that there was no prescribing information or generic...

Breach Clause(s): 3.1, 4.1, 4.3, 9.1, 2

Applicable Code: 2019

Received: 24 October 2019

Completed: 18 February 2020

A named, contactable complainant stated that Bracco had employed representatives, without ABPI qualifications, to sell medicines. The representatives had been with Bracco for at least 3 years. The complainant alleged that Bracco had ignored the Code requirements in this regard. The complainant alleged that a named representative had not sat the ABPI examination within his/her first two years of being a representative. The complainant provided a screenshot of an advertisement for CTExprès syringe-less CT injector which...

Breach Clause(s): 4.1, 9.1, 16.3

No breach Clause(s): 16.1

Applicable Code: 2019

Received: 16 October 2019

Completed: 13 February 2020

An anonymous individual complained about unethical behaviour by Merz across the UK and Ireland with regard to Bocouture (botulinum toxin type A). The complainant alleged cross border trading of Bocouture from Northern Ireland where it was licensed into the Republic of Ireland where it was not licensed. The complainant alleged that Bocouture was ordered and picked up by a Merz employee from a distributor in Northern Ireland and delivered to a customer at a named medical...

Breach Clause(s): 9.1, 15.2

No breach Clause(s): 2, 3.1, 9.1, 15.2

Applicable Code: 2019

Received: 24 October 2019

Completed: 13 February 2020

A complainant who described him/herself as a concerned UK health professional, alleged that the Invokana content hosted on the website appeared to be promotional. As there was no prescribing information or unique identifier, the complainant was concerned that the material had not been appropriately approved by the company. Invokana, marketed by Napp Pharmaceuticals Ltd, was used in the treatment of adults with insufficiently controlled type 2 diabetes as an adjunct to diet and exercise. The...

Breach Clause(s): 4.1

No breach Clause(s): 14.1

Applicable Code: 2019

Received: 07 October 2019

Completed: 12 February 2020

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