AUTH/3597/1/22 - Complainant v AstraZeneca

AstraZeneca on LinkedIn

  • Received
    05 January 2022
  • Case number
  • Applicable Code year
  • Completed
    08 August 2023
  • No breach Clause(s)
  • Breach Clause(s)
  • Sanctions applied
    Undertaking received
  • Additional sanctions
  • Appeal
    Appeal by respondent

Case Summary

This case was in relation to  two posts on LinkedIn and a BBC Radio 4 interview about AstraZeneca and an alleged breach of undertaking .   

The Panel ruled a breach of the following Clause(s) of the 2021 Code on the basis that:

  • The first LinkedIn post in question by a very senior AstraZeneca UK employee which included a link to an inews article promoted AstraZeneca’s Covid-19 vaccine prior to the grant of its marketing authorisation (Matter 1)
  • A UK-based global employee’s like of the second LinkedIn post disseminated positive information about Evusheld to the employee’s connections and promoted the medicine prior to the grant of its marketing authorisation (Matter 2)The Panel considered, noting the content of the video transcript provided by AstraZeneca in relation to the BBC interview, that the interview given by the very senior AstraZeneca employee had promoted AstraZeneca’s Covid-19 vaccine prior to the grant of its marketing authorisation (Matter 3) The Panel noted its three rulings of a breach of high standards in relation to the promotion of an unlicensed medicine in the three separate matters above, two of which resulted from the actions of very senior employees and it appeared that in relation to the first LinkedIn post both a very senior employee and AstraZeneca had failed to recognise the promotional nature of the LinkedIn post resulting in the placement of an uncertified promotional post on the senior employee’s personal LinkedIn account. 



Breach of Clause 5.1

(Successfully appealed in Matters 1 and 3. Unsuccessfully appealed in Matter 2)

Failing to maintain high standards

Breach of Clause 2

(Successfully appealed )

Bringing discredit upon, and reducing confidence in, the pharmaceutical industry

 The Panel ruled no breach of the following Clause(s) of the 2021 Code on the basis that:

  • the matters before it in this case were sufficiently different to Case AUTH/3412/10/20 such that there had been no breach of the undertaking given in that case,
  • the complainant had not established that the BBC interview had been used in many other publications which showed lax processes or that statements made during the interview were not capable of substantiation,
  • Clause 8.3 was not relevant as in the Panel’s view the two LinkedIn posts and interview were promotional, and
  • Clauses 26.1 and 26.2 only applied to prescription only medicines and neither AstraZeneca’s Covid vaccine was not classified as such at the time the first LinkedIn post was made or the interview took place and an edited video of it was hosted on the BBC website and nor was Evusheld at the time the second LinkedIn post was liked by the UK-based employee.

No Breach of Clause 2

Requirement that activities or materials must not bring discredit upon, or reduce confidence in, the pharmaceutical industry

No Breach of Clause 3.3

Requirement to comply with an undertaking

No Breach of Clause 5.1

Requirement to maintain high standards

No Breach of Clause 6.2

Requirement that information must be capable of substantiation

No Breach of Clause 8.3

Requirement to certify non-promotional material

No Breach of Clause 26.1

Requirement not to advertise prescription only medicines to the public

No Breach of Clause 26.2

Requirement that information about prescription only medicines which is made available to the public must be factual, balanced, must not raise unfounded hopes of successful treatment or encourage the pubic to ask their health professional to prescribe a specific prescription only medicine


The Panel’s ruling of a breach of Clause 5.1 in relation to Matters 1 and 3 was overturned and upheld in relation to Matter 2 at appeal.  The Panel’s overall ruling of a breach of Clause 2 in relation to Matters 1-3 was overturned at appeal. 

This summary is not intended to be read in isolation.
             For full details, please see the full case report below.