Advert - Novo Nordisk – Case AUTH/3847/11/23

• Date posted
  05 July 2024
• Sanction
  Advertisement,

For its failure to disclose transfers of value of approximately £7.8 million, relating to over 150 different bodies, across a three-year period (2020-2022) selected as part of its voluntary admission, Novo Nordisk was ruled in breach of the following clauses of the 2019 Code and 2021 Code:

2019 Code

Clause 2 - Bringing discredit upon, and reducing confidence in, the pharmaceutical industry
Clause 9.1 - Failing to maintain high standards
Clause 23.2 - Failing to publicly disclose details of the fees paid to consultants in the UK for certain services rendered by them
Clause 24.1 - Failing to document and publicly disclose annually certain transfers of value made directly or indirectly to health professionals, other relevant decision makers and healthcare organisations
Clause 24.4 - Failing to make disclosures annually in respect of each calendar year in the first six months after the end of the calendar year in which the transfers of value were made
Clause 27.7 - Failing to make publicly available a list of patient organisations to which it provides supports
Clause 27.8 - Failing to meet the disclosure requirements when engaging patient organisations

2021 Code

Clause 2 - Bringing discredit upon, and reducing confidence in, the pharmaceutical industry
Clause 5.1 - Failing to maintain high standards
Clause 24.4 - Failing to disclose annually details of the fees and expenses paid to UK individuals, organisations etc for contracted services
Clause 24.6 - Failing to meet the disclosure requirements for fees and expenses for contracted services
Clause 28.1 - Failing to document and publicly disclose annually certain transfers of value made directly or indirectly to health professionals, other relevant decision makers and healthcare organisations
Clause 29.1 - Failing to make publicly available annually, a list of patient organisations to which it provides donations, grants or sponsorship or with whom it has engaged to provide contracted services over the reporting period
Clause 29.2 - Failing to meet the disclosure requirements for the provision of donations, grants or sponsorship to a patient organisation
Clause 30.1 - Failing to make publicly available annually details of the fees for certain contracted services paid to members of the UK public, including patients and journalists
Clause 31.1 - Failing to make disclosures annually in respect of each calendar year in the first six months after the end of the calendar year in which the transfers of value were made.

The Code of Practice Appeal Board required Novo Nordisk to be publicly reprimanded for its failings with regards to its failure to disclose transfers of value over a sustained period.