Clause 28 - The Internet and other Digital Platforms

​28.1 Promotional material about prescription only medicines directed to a UK audience which is provided on the Internet must comply with all relevant requirements of the Code.

  • Clause 28.1 Access

    Unless access to promotional material about prescription only medicines is limited to health professionals and other relevant decision makers, a pharmaceutical company website or a company sponsored website must provide information for the public as well as promotion to health professionals with the sections for each target audience clearly separated and the intended audience identified. This is to avoid the public needing to access material for health professionals unless they choose to. The MHRA Blue Guide states that the public should not be encouraged to access material which is not intended for them.

most recent cases See all Applicable Code year
Applicable Code year

Please check the date of the Code that applies to the Case that you are looking at. The date of the complaint may vary from the activity/material alleged to have been in breach.

AUTH/3488/3/21 - Complainant v AstraZeneca Breach: 4.1, 4.3, 4.4, 9.1, 14.1 No breach: 2, 4.3, 7.2, 7.4, 7.9, 7.10, 9.1, 9.7, 26.1, 26.2, 28.1 Applicable Code: 2019 Received: 10 March 2021 Completed: 29 September 2021 AUTH/3463/1/21 - Complainant v Lundbeck Breach: 14.5 No breach: 2, 3.1, 4.1, 4.9, 9.1, 12.1, 14.1, 14.3, 26.1, 26.2, 28.1 Applicable Code: 2019 Received: 25 January 2021 Completed: 27 September 2021 AUTH/3466/2/21 - Complainant v Lundbeck Breach: 9.1, 14.3 No breach: 2, 9.1, 14.1, 14.3, 28.1 Applicable Code: 2019 Received: 01 February 2021 Completed: 27 September 2021 AUTH/3406/10/20 - Complainant v Chiesi No breach: 2, 7.2, 8.1, 9.1, 26.1, 28.1, 28.3 Applicable Code: 2019 Received: 23 October 2021 Completed: 16 September 2021 AUTH/3405/10/20 - Complainant v Leo Breach: 4.1, 4.5, 4.6, 4.9, 9.1, 14.1, 14.3, 28.1 No breach: 2, 3.1, 4.1, 4.2, 4.3, 4.4, 4.5, 4.6, 4.8, 4.9, 9.10, 14.1, 14.3, 16.1, 18.1, 26.1, 26.2, 26.3, 28.1, 28.3 Applicable Code: 2019 Received: 25 October 2020 Completed: 10 September 2021 AUTH/3400/10/20 - Complainant v Novartis Breach: 2, 3.1, 9.1, 9.10, 12.1, 14.1, 28.1 No breach: 26.1, 26.2 Applicable Code: 2019 Received: 18 October 2020 Completed: 16 August 2021 AUTH/3450/1/21 - Complainant v Lundbeck Breach: 4.1, 4.9, 9.1, 14.1 No breach: 2, 26.1, 26.2, 28.1, 28.3 Applicable Code: 2019 Received: 05 January 2021 Completed: 05 August 2021 AUTH/3404/10/20 - Indivior v Camurus Breach: 2, 4.1, 4.3, 4.9, 9.1, 9.10, 12.1, 14.1, 26.1, 26.2, 28.1 No breach: 9.10 Applicable Code: 2019 Received: 22 October 2020 Completed: 22 June 2021 AUTH/3417/11/20 - Complainant v Daiichi-Sankyo Breach: 9.1, 9.10, 22.4 No breach: 2, 4.1, 4.2, 4.5, 4.4, 4.6, 4.8, 4.9, 4.10, 9.1, 11.1, 12.1, 14.1, 14.5, 14.6, 23.1 , 26.1, 28.1 Applicable Code: 2019 Received: 09 November 2020 Completed: 27 May 2021 AUTH/3388/9/20 - Complainant v Daiichi-Sankyo Breach: 4.1, 4.3, 4.6, 4.8, 4.9, 4.10, 9.1, 24.1 No breach: 2, 26.1, 27.2, 27.9, 28.1 Applicable Code: 2019 Received: 24 September 2020 Completed: 22 April 2021 AUTH/3357/5/20 - Complainant v Colonis AUTH/3357/5/20 - Complainant v Colonis No breach: 2, 9.1, 26.1, 28.1 Applicable Code: 2019 Received: 29 May 2020 Completed: 11 February 2021 AUTH/3272/10/19 - Complainant v ViiV Breach: 28.1 Applicable Code: 2019 Received: 25 October 2019 Completed: 05 October 2020 AUTH/3271/10/19 - Complainant v Napp Breach: 7.2, 7.9, 9.1, 26.1, 28.1 No breach: 2, 4.1, 7.4 Applicable Code: 2019 Received: 28 October 2019 Completed: 25 September 2020 AUTH/3270/10/19 - Complainant v Bayer Breach: 9.1 No breach: 2, 26.1, 26.2, 28.1 Applicable Code: 2019 Received: 25 October 2019 Completed: 05 August 2020 AUTH/3263/11/19 - Anonymous v Almirall Breach: 7.2, 7.4, 9.1, 28.1 No breach: 2, 12.1, 14.1, 14.3, 26.1, 28.1 Applicable Code: 2019 Received: 17 October 2019 Completed: 05 August 2020 AUTH/3303/1/20 - Anonymous complainant v Vifor Breach: 7.2, 7.4, 9.1, 26.1, 28.1, 28.3 No breach: 2, 4.1, 4.9, 7.2, 7.4, 9.1, 26.3 Applicable Code: 2019 Received: 23 January 2020 Completed: 03 August 2020 AUTH/3273/10/19 - Complainant v Gedeon Richter Breach: 4.3, 9.1 No breach: 2, 12.1, 26.1, 28.1 Applicable Code: 2019 Received: 28 October 2019 Completed: 24 April 2020 AUTH/3203/6/19 - Anonymous employee v Otsuka Europe Breach: 9.1, 26.1, 26.2, 28.1 No breach: 2, 9.1, 26.2 Applicable Code: 2019 Received: 07 June 2019 Completed: 23 April 2020 AUTH/3238/8/19 - Anonymous v Vifor Breach: 4.10, 28.1 Applicable Code: 2019 Received: 12 August 2019 Completed: 26 March 2020 AUTH/3252/10/19 - Complainant v Lilly Breach: 9.1, 26.1, 28.1 No breach: 2 Applicable Code: 2019 Received: 07 October 2019 Completed: 07 February 2020

28.2 Information or promotional material about medicines covered by Clause 28.1 which is placed on the Internet outside the UK will be regarded as coming within the scope of the Code, if: 

  • it was placed there by a UK company/with a UK company’s authority, or
  • it was placed there by an affiliate of a UK company, or with the authority of such a company and it makes specific reference to the availability or use of the medicine in the UK.

28.4 A medicine covered by Clause 28.1 may be advertised in a relevant independently produced electronic journal intended for health professionals or other relevant decision makers which can be accessed by members of the public.

28.5 Public assessment reports (European or UK), summaries of product characteristics, package leaflets and reference material for prescription only medicines may be included on the Internet and be accessible by members of the public provided that they are not presented in such a way as to be promotional in nature.

  • Clause 28.5 MHRA Guidance

    The MHRA Blue Guide states that the public should not need to access non-UK websites or non-UK parts of websites to obtain basic information about a company’s products, such as package leaflets, summaries of product characteristics, public assessment reports and other non-promotional material. It is good practice for each page of a company website to include a statement identifying the intended audience.

  • Clause 28.5 Information on Clinical Trials

    Information on clinical trials as agreed in the current Joint Position on the Disclosure of Clinical Trial Information via Clinical Trial Registries and Databases and the current Joint Position on the Publication of Clinical Trial Results in the Scientific Literature may be available at a UK or a non UK website.

    Attention is drawn to Clause 13.1 and its supplementary information.

28.6 It should be made clear when a user is leaving any of the company’s sites, or sites sponsored by the company, or is being directed to a site which is not that of the company.