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Sarbanes-Oxley Act 2002

Following a number of corporate and accounting scandals in the USA, Congress passed the Sarbanes-Oxley Act of 2002 (Sarbanes-Oxley). Sarbanes-Oxley established new and enhanced standards for corporate accountability in the USA. Although GSK's corporate governance structure was believed to be robust and in line with best practice, certain changes were necessary to ensure compliance with Sarbanes-Oxley.

Sarbanes-Oxley code of ethics
Section 406 of Sarbanes-Oxley, "Code of Ethics for Senior Financial Officers" (the code), requires that GSK has a code of ethics "applicable to its Principal financial officer and comptroller or Principal accounting officer, or persons performing similar functions". There have been no changes in or waivers to the company's code of ethics which require disclosure in accordance with Sarbanes-Oxley.

The code is defined as standards that promote:

1. honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;
2. full, fair, accurate, timely, and understandable disclosure in the periodic reports required to be filed by the issuer; and
3. compliance with applicable governmental rules and regulations.

GSK formulated a Sarbanes-Oxley code of ethics comprised of seven GSK policies:

• Code of conduct
• Company assets and proprietary information
• External communications to investors and media; External speaking engagements and publications
• Political contributions
• Preventing corrupt practices and maintaining standards of documentation
• Risk management and legal compliance
• Share dealing

Our code of ethics goes beyond the requirements of Sarbanes-Oxley in that it is applicable to all GSK employees. The Chief Executive Officer, Chief Financial Officer, as well as the Senior Vice President, Financial Controller and the Senior Vice President, Finance Services have all signed statements certifying their compliance with the code of ethics.

Document downloads
The following PDFs open in a new window.

• Code of Conduct (PDF 89Kb)
• Protection of GSK Information PDF (88Kb)
• External Communications to Investors and Media; External Speaking Engagements and Publications PDF (0.01Mb)
• Political Contributions PDF (0.01Mb)
• Preventing Corrupt Practices and Maintaining Standards of Documentation PDF (0.01Mb)
• Risk Management and Legal Compliance PDF (0.01Mb)
• Code for Dealing in Securities PDF (164Kb)