In the last 4 years, Pfizer, Moderna and AstraZeneca have been found guilty of breaching the UK pharmaceutical code of practice in 53 separate offences concerning their covid injections.

In some cases, the pharmaceutical companies were found guilty of promoting vaccines to the public which is unlawful in the UK.  Yet it appears no action was taken.

UsForThem, a UK campaign group for children, tweeted a video yesterday summarising the complaints made to the PMCPA where Pfizer, Moderna and AstraZeneca’s activities relating to the companies’ covid “vaccines” were found to be in breach of the British Pharmaceutical Industry Code of Practice.

The text accompanying USForThem’s video stated, “The litany of serious and persistent offending includes:

• misleading the public about the safety and efficacy of their vaccines;
• bringing discredit on the pharmaceutical industry;
• improper marketing of their products to children; and
• bribery.”

The video concludes, “Despite a track record of serious and persistent offending, no fines or other penalties have been imposed by the regulator.  The UK’s pharma regulatory system is broken.”

The Prescription Medicines Code of Practice Authority (“PMCPA”) is the self-regulatory body which administers the Association of the British Pharmaceutical Industry (“ABPI”) Code of Practice for the Pharmaceutical Industry. 

The PMCPA is responsible for providing advice, guidance and training on the ABPI Code. It also investigates complaints about pharmaceutical companies’ activities and ensures compliance with the ABPI Code of Practice.

Companies found in breach of the Code are required to pay administrative charges, provide a written undertaking, and may be subject to additional sanctions. One of the sanctions PMCPA can impose is to report a company to the Code of Practice Appeal Board, either because a particular case warrants such or because repeated breaches of the Code raise concerns about the company’s procedures.  The Board consists of 10 members, four of which represent pharmaceutical companies.

The PMCPA cannot issue fines but it can suspend or expel a pharmaceutical company from the ABPI, which must be ratified by the ABPI Board.  The ABPI is a trade association so expulsion means the company loses the benefits of ABPI membership, such as representation, advocacy, and access to industry events and resources.

The ABPI Code of Practice sets standards for its members for the promotion of medicines to health professionals and other relevant decision-makers in the UK.  It includes requirements for the provision of information to patients and the public and outlines guidelines for interactions with patient groups. The code aims to ensure that pharmaceutical companies operate in a responsible, ethical and professional manner.

You can find all the complaints made to the PMCPA HERE.  A number of the complaints relate to pharmaceutical companies attempting to advertise or market their products on social media.

Although pharmaceutical companies are allowed to promote medicines to healthcare professionals and other relevant decision-makers, the ABPI Code of Practice prohibits the advertising or promotion of prescription-only medicines to the public according to UK law.  Under UK law, vaccines are classified as prescription-only medicines.

The PMCPA website uses Boolean search which allows a combination of words and phrases using the operators AND, OR, and NOT to either narrow, broaden or define search criteria.  For example, we wanted to search for instances where Pfizer had failed to maintain high standards relating to its covid injection.  So, in the search box we entered: “Pfizer” AND “COVID” AND “high standards.”  38 results were returned across various PMCPA categories: “Completed Cases,” “Advertised Sanctions” and “Code.” 

The same case can appear in more than one category. An explanation of what the categories are explains why.

Once evidence from both parties is considered for a complaint and the case has concluded, a case report is published on the PMCPA’s website as a “Completed Case.”

“Advertised Sanctions” refers to companies that have been ruled to be in breach of Clause 2 of the ABPI Code (Upholding Confidence in the Industry), are required to issue a corrective statement or are the subject of a public reprimand.   In these cases, the PMCPA advertises brief details of the case in the medical and pharmaceutical press, namely the British Medical Journal and the Nursing Standard.

The “Code” category is either a short explanation of a clause within the APBI Code of Practice or a list of recent complaint cases relating to a particular code.

To give an idea of the type of information a complaint and a case report includes, below is the case summary for one of the results returned from our search, “Pfizer” AND “COVID” AND “high standards,” from the “Completed Case” category. 

Our selected case relates to a complaint received from “a contactable member of the public” about Pfizer’s misuse of social media to misleadingly and illegally promote their covid vaccine.  Although we have only reproduced the summary, you can find the full report by following the hyperlink contained in the subheading below (emphasis our own).

AUTH/3741/2/23 – Complainant v Pfizer: Promotional use of Twitter

This case concerned a complaint received in February 2023 about a tweet posted by a US employee of Pfizer, and re-tweeted by a senior UK employee in November 2020. The tweet, which was still visible on their Twitter feed, related to a Pfizer and BioNTech press release announcing the conclusion of the Phase 3 Study of Pfizer’s COVID-19 vaccine candidate, which had met all primary efficacy endpoints. The complainant alleged the tweet included relative efficacy rates without any information about absolute efficacy rates and that no safety data or safety information was provided, and therefore that Pfizer had misleadingly and illegally promoted its COVID-19 vaccine.

The Panel ruled a breach of the following Clauses of the 2019 Code:

Breach of Clause 2: Bringing discredit upon, and reducing confidence in, the pharmaceutical industry

Breach of Clause 3.1: Promoting an unlicensed medicine

Breach of Clause 7.2: Making a misleading claim

Breach of Clause 7.9: Making claims that did not reflect the available evidence regarding possible adverse reactions

Breach of Clause 9.1: Failing to maintain high standards

Vaccines are prescription-only medicines, whether licensed or unlicensed.  Under UK law, advertising or promotion of prescription-only medicines to the public is prohibited.  Did PMCPA report this violation to authorities?  If not, why not?

The complaint above was received by PMCPA on 15 February 2023 and completed a year later on 1 March 2024.  After receiving details of the complaint from PMCPA, Pfizer discovered that four other Pfizer employees in the UK had re-tweeted the same post that was the subject of the complaint.  The full report notes that the re-tweets by Pfizer employees have been deleted but doesn’t mention when this happened.  It could have been within a day of Pfizer being contacted by PMCPA or it could have been many months later.  The re-tweets had been publicly visible for more than two years by the time the complaint was made.

Although it’s not clear how efficient or effective PMCPA’s complaints procedure is, if you see pharmaceutical companies breaching the ABPI Code of Practice you can submit a complaint to PMCPA HERE.

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