CASE/0587/05/25
COMPLAINANT v ASTRAZENECA
Alleged promotion on LinkedIn
CASE SUMMARY
This case was in relation to a LinkedIn post that was ‘liked’ by an AstraZeneca employee. The complainant alleged that the post was promotional for Trixeo Aerosphere because it mentioned the brand name and indication alongside “a claim that Trixeo is safe and effective”. The complainant also alleged that liking the post was “disparaging towards other fixed triple pMDI inhalers”.
The outcome under the 2024 Code was:
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Using the word 'safe' without qualification
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No Breach of Clause 5.1
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No Breach of Clause 6.6
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This summary is not intended to be read in isolation.
For full details, please see the full case report below.
FULL CASE REPORT
A complaint was received about AstraZeneca UK Limited from a contactable complainant who described themselves as a health professional.
COMPLAINT
The complaint wording is reproduced below:
“The MHRA have placed the following post on their linkedin channel: New treatment approved: Low-carbon version of COPD inhaler Trixeo Aerosphere. We have approved a low-carbon version of Trixeo Aerosphere, a triple combination inhaler for adults with moderate to severe chronic obstructive pulmonary disease (COPD). It uses the propellant, HFO-1234ze(E), and is as safe and effective as the previous version. The link to the post is – [URL provided] This post has been liked by an Astrazeneca employee. The employee name is [named] who is a UK [employee’s job title]. The linkedin profile for the employee is: [URL provided] Considering the employee is in a senior role, it is concerning that [they have] liked a product post from the MHRA concerning Astrazeneca product which brings it into the scope of the ABPI code. Furthermore liking a independent post which is from the MHRA is also disparaging towards other fixed triple pMDI inhalers currently on the market that are looking to be launched with a new propellant soon. The MHRA post stipulates both the brand name and indication alongside a claim that Trixeo is safe and effective. As the connections for the Astrazeneca employee include both members of the public and healthcare professionals there are several breaches of promotion to the public and healthcare professionals. Breaches of the ABPI code include: 26.1, 26.2, 12.1, 12.3, 12.4, 12.6, 6.4, 5.1 and clause 2.”
When writing to AstraZeneca, the PMCPA asked it to consider the requirements of Clauses 26.1, 26.2, 12.1, 12.3, 12.4, 12.6, 6.4, 5.1 and 2 of the 2024 Code as cited by the complainant and, in addition, Clause 6.6.
ASTRAZENECA’S RESPONSE
The response from AstraZeneca is reproduced below:
“We are writing to you in response to your letter dated 23 May 2025, concerning a complaint from an HCP with respect to a LinkedIn post about approval of Trixeo with new propellant HFO-1234ze(E) for moderate to severe COPD.
The LinkedIn post was posted by the MHRA, which read: “New treatment approved: Low-carbon version of COPD inhaler Trixeo Aerosphere. We have approved a low-carbon version of Trixeo Aerosphere, a triple combination inhaler for adults with moderate to severe chronic obstructive pulmonary disease (COPD). It uses the propellant, HFO-1234ze(E), and is as safe and effective as the previous version.” The complainant's allegations are as follows:
1. Post was liked by a UK AstraZeneca employee in a senior role, which has disseminated the information to members of the public and healthcare professionals.
2. Post is considered promotional as a result, as it mentions Trixeo, COPD and claims that it is safe and effective.
3. Liking the post is disparaging towards other fixed triple pMDI inhalers currently on the market that are looking to launch with a new propellant soon.
We will address each of the complainant’s allegations according to the relevant clauses of the ABPI Code of Practice (clauses 26.1, 26.2, 12.1, 12.3, 12.4, 12.6, 6.4, 6.6, 5.2 [sic] and 2).
Additional information requested by PMCPA
The LinkedIn post by MHRA was liked by one AZ employee, who (at the time the complaint was received) has [over three thousand] followers and 500+ connections on LinkedIn. Although this is primarily a professional channel, we are unable to determine status of each of these (i.e. whether they are members of the public or healthcare professionals).
The employee cited in the complaint is not considered a senior leader based on their role in the organisation. The employee has completed the following training regarding social media use:
1. Global Standard for Employee Use of Personal Social Media training completed [November 2023].
2. AZUK Social media initiatives SOP training completed [November 2023], which also outlines how employees can engage with social media.
3. Attended Quarterly PMCPA Case review training in September 2024, where a social media case was discussed. Employees were reminded in this session not to ‘like’ social media posts with product mention.
AstraZeneca Response to the allegations
The post announces MHRA approval of Trixeo for moderate to severe COPD, with a new low carbon propellant (LCP). HFO-1234ze(E) is the first LCP to be approved by the MHRA for a pMDI. AstraZeneca was not involved in the creation or development of the MHRA LinkedIn post.
AstraZeneca does not regard the LinkedIn post by MHRA to be promotional for the following reasons:
• The LinkedIn post is a factual announcement about a regulatory update, posted by the UK regulator.
This is aligned to the PMCPA panel’s view in Case AUTH/3892/4/24 (e.g. tweet 1: "Today, in the UK, the MHRA has approved our COVID-19 vaccine for emergency supply” regarded a factual non-promotional post).
• Although mention of brand name may be considered as promotional in tone, we deem mention of the brand name ‘Trixeo’ appropriate in this instance as the propellant HFO-1234ze(E) was approved for use with Trixeo only.
• The post makes no claims for Trixeo.
The post makes it explicitly clear that the approval is in relation to a low carbon version of the medicine in the first sentence: “New treatment approved: Low-carbon version of COPD inhaler Trixeo Aerosphere”. The statement later in the post: “It uses the propellant, HFO-1234ze(E), and is as safe and effective as the previous version” clearly refers only to the propellant. In order to obtain MHRA approval, the propellant must demonstrate comparable efficacy and safety in bioequivalence studies, which has been referred to here. The propellant is an excipient of the medicine and not a prescription-only medicine itself. The post is therefore not referring to the efficacy and safety of Trixeo as the complainant has alleged.
The complainant alleged that liking the post was disparaging towards other fixed triple pMDI inhalers. We are unsure why announcing the approval of an LCP by the regulator is disparaging towards other pMDI inhalers currently on the market. There is no reference to other fixed triple pMDI inhalers in the post which was created by the MHRA.
AstraZeneca UK has provided training on social media use and had a robust policy in place for employees. We therefore maintain that the company has maintained high standards.
For the reasons outlined above and the non-promotional nature of the post, we refute breaches of Clauses 26.1, 26.2, 12.1, 12.3, 12.4, 12.6, 6.4, 6.6, 5.1 and 2 of the Code.
Summary of AstraZeneca’s position
It is AstraZeneca’s position that:
1. The LinkedIn post is a non-promotional factual announcement about a regulatory update.
2. There are no claims related to the safety and efficacy of Trixeo.
3. The LinkedIn post is not disparaging towards other fixed triple pMDI inhalers.
AstraZeneca is fully committed to the ABPI Code of Practice and takes its responsibilities under the code very seriously.”
PANEL RULING
This case was about a LinkedIn post that was ‘liked’ by an AstraZeneca employee. The complainant alleged that the post was promotional for Trixeo Aerosphere because it mentioned the brand name and indication alongside “a claim that Trixeo is safe and effective”. The complainant also alleged that liking the post was “disparaging towards other fixed triple pMDI inhalers”.
The original post was made by the Medicines and Healthcare products Regulatory Agency (MHRA). The Panel accepted AstraZeneca’s submission that AstraZeneca was not involved in the creation or development of the post. As such, the Panel determined that the Code did not apply to the original post.
AstraZeneca acknowledged that the post had been ‘liked’ by the AstraZeneca employee identified by the complainant. In the Panel’s view, the UK-based employee’s engagement with the post would have proactively disseminated it to their LinkedIn connections and followers. The Panel determined that this brought the LinkedIn post within the scope of the Code. It was well established that if an employee’s personal use of social media was found to be in scope of the Code, the company would be held responsible.
The Panel noted AstraZeneca’s submission that it could not determine whether each of the employee’s connections and followers was a member of the public or a health professional. In the Panel’s view, however, it was likely that the employee’s [more than three thousand] followers and 500+ connections would include UK members of the public and health professionals.
The Panel disagreed with AstraZeneca’s submission that the post was not promotional for Trixeo. The Panel took into account the following:
• The brand name (Trixeo Aerosphere) was mentioned four times in the post, including in the accompanying image.
• The post included the indication: “a triple combination inhaler for adults with moderate to severe chronic obstructive pulmonary disease (COPD)”.
• The post included several claims: “low-carbon”, “used to help ease breathing, reduce symptoms, and prevent flare-ups of COPD”, “a widely used COPD treatment”, “as safe and effective as the previous version”, and “without compromising on safety, quality or clinical benefit”.
The Panel considered that there was a difference between the MHRA publishing such a post and its subsequent dissemination by an employee of the pharmaceutical company that sold the medicine.
The Panel considered that the proactive dissemination of the LinkedIn post by the AstraZeneca UK employee constituted promotion of a prescription only medicine to the public and might encourage a member of the public to ask their health professional for Trixeo Aerosphere. The Panel therefore ruled breaches of Clauses 26.1 and 26.2.
The Panel considered, on the balance of probabilities, that the proactive dissemination of the LinkedIn post by the UK employee also constituted promotion of a prescription only medicine to UK health professionals. The requirements for prescribing information and other obligatory information would, therefore, be applicable. The Panel observed that the LinkedIn post was disseminated by the AstraZeneca employee to health professionals without prescribing information, a statement as to where prescribing information could be found, or the non-proprietary name. While the post included a link to the Yellow Card scheme website, it did not include the mandatory wording specified in Clause 12.6. The Panel therefore ruled breaches of Clauses 12.1, 12.3, 12.4 and 12.6.
The complainant alleged a breach of Clause 6.4 and had quoted the first part of the post, which included the statement:
“It uses the propellant, HFO-1234ze(E), and is as safe and effective as the previous version”.
The Panel disagreed with AstraZeneca’s submission that this statement referred only to the propellant. The use of the words “it” and “and” meant that the “as safe and effective” description applied to the “low-carbon version of Trixeo Aerosphere” in the previous sentence.
Clause 6.4 required that information and claims about adverse reactions must reflect available evidence or be capable of substantiation by clinical experience. It must not be stated that a product has no adverse reactions, toxic hazards or risks of addiction or dependency. The word ‘safe’ must not be used without qualification.
In the Panel’s view, the phrasing “It … is as safe and effective as the previous version…” without any safety information about Trixeo Aerosphere in the post, meant the employee had disseminated material which described both versions of Trixeo Aerosphere as ‘safe’ without the necessary qualification. The Panel therefore ruled a breach of Clause 6.4.
The case preparation manager had raised Clause 6.6 in relation to the complainant’s allegation that “liking an independent post which is from the MHRA is also disparaging towards other fixed triple pMDI inhalers currently on the market that are looking to be launched with a new propellant soon.” Clause 6.6 required that the medicines, products and activities of other pharmaceutical companies must not be disparaged. The Panel noted that the LinkedIn post made no reference to any other company’s products. In the Panel’s view, promotion of the features of one product did not necessarily constitute disparagement of another company’s products. The Panel ruled no breach of Clause 6.6.
The Panel took account that AstraZeneca had a social media policy at the time of the engagement in question, which clearly stated “Employees must not post, share links to, or engage with content related to products, marketed or in development”. The policy clearly defined “engage with” as encompassing reactions such as a ‘like.’
The Panel accepted AstraZeneca’s submission that the employee in question was not a senior leader and that they had been trained on the social media policy. The Panel took into account AstraZeneca’s submission that the employee in question had also attended training within the last 12 months where employees were reminded not to ‘like’ social media posts that mentioned a product.
The Panel considered that AstraZeneca had been let down by the employee who had acted contrary to company policy and training. The Panel therefore ruled no breach of Clause 5.1.
Clause 2 was a sign of particular censure and reserved for such use. The Panel considered that the multiple breach rulings above adequately covered the matter and ruled no breach of Clause 2.
Complaint received 20 May 2025
Case completed 22 December 2025
