Public reprimand - Allergan Limited – Case AUTH/3431/11/20

Allergan has been publicly reprimanded by the Code of Practice Appeal Board for its widespread use of social media which promoted a prescription only medicine to the public.

In Case AUTH/3431/11/20 the Code of Practice Panel ruled breaches of the Code including a breach of Clause 2 in that on multiple occasions Allergan employees had either directed others to or had proactively distributed posts that promoted a prescription only medicine, Botox (botulinum toxin type A) on social media; it was particularly concerned about the terminology used in some of those posts.  High standards had not been maintained.  Allergan unsuccessfully appealed the Panel’s rulings except for one ruling where the Appeal Board ruled no breach of Clause 26.1.

The Appeal Board was extremely concerned that Allergan employees had either directed others to or had proactively distributed posts that promoted a prescription only medicine to the public on social media; it was particularly concerned about the terminology used in some of the posts.  The Appeal Board noted its comments and rulings and considered that in the repeated promotion of a prescription only medicine to the public and trivialising the use of a prescription only medicine Allergan had reduced confidence in, and brought discredit upon, the pharmaceutical industry.  The Appeal Board upheld the Panel’s ruling of a breach of Clause 2.