An aesthetics clinic owner/medical director complained that Allergan Limited promoted Botox (botulinum toxin type A), a prescription only medicine (POM), on social media.The complaint focused on content on the JuvedermUK patient-facing Instagram account (Juvederm is a dermal filler registered as a medical device) that included Botox pack shots.Two Instagram Stories reposted on the JuvedermUK account contained Botox packaging: one still image with a Botox pack shot in the foreground, and one video where a Botox vial/carton appeared in the background…
The Panel considered whether the company had maintained high standards throughout. Evidence reviewed included internal communications, the promotional material in question and the response from the medical information team. The case raised questions about clause 5.1 compliance and the adequacy of the certification process under clause 8.
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