Global compliance

Overview

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The Global Compliance function is responsible for supporting the development and implementation of practices that facilitate employees’ compliance with laws and Group policy

The thrust of our compliance efforts is the promotion of ethical behaviour and corporate responsibility in accordance with our values and due diligence in preventing and detecting misconduct or non-compliance with laws or regulations, supported by effective compliance systems.

Our employees are encouraged to seek help and to report concerns or suspected cases of misconduct without the fear of retaliation.  Employees can do this through line management or confidentially through our Speak Up Integrity reporting channels.  All concerns and allegations are fairly and independently investigated and disciplinary action, if applicable, is commensurate with the issues presented.

The Global Compliance organisation comprises three groups:

  • Global Compliance Business Partners, who are aligned to each business unit.  Their role is to proactively partner with senior leaders to drive a values and compliance-based culture and improve risk identification and management practices;
  • Global Compliance Operations centrally manages our compliance activities (e.g. analytics, reporting, communications, policy administration, project management and training), with a focus on efficiency, consistency and continuous improvement;
  • Global Compliance Investigations co-ordinates all compliance-related investigations, ensuring consistency and efficiency of investigations across geographies and business units.   
Global Compliance contact information
Global Compliance Business Partners Contact Details
Nick Hirons - SVP, Governance, Ethics & Assurance Email: Nick.J.Hirons@gsk.com
  UK Phone: +44 (0) 20 8047 4501
Sean Roberts - SVP Legal Ops & Compliance Officer - Consumer Healthcare Email: Sean.J.Roberts@gsk.com
  US Phone: + 44 (0) 20 8047 4614
Anne Belcher - VP Compliance Officer - Emerging Markets, Asia Pacific, Japan Email: Anne.Belcher@gsk.com
  Indonesia phone: + 62 21 2553 2350
Aggie Gallagher – VP Compliance Officer – GSK Vaccines Email: Aggie.A.Gallagher@gsk.com
  Belgium Phone: + 32 10 85 1724
Guy Wingate – VP Compliance Officer – Global Manufacturing & Supply Email: Guy.AS.Wingate@gsk.com
  UK Phone: + 44 1833 69 3330
Rob Macrae - VP Compliance Officer - Research and Development Email: Rob.R.MacRae@gsk.com
  US Phone: + 1 215 7517375
Michael Shaw – VP Compliance Officer - North America Pharmaceuticals Email: Michael.L.Shaw@gsk.com
  US Phone: + 1-215-751-7337

 

Speak Up Integrity lines

Global Ethics & Compliance oversees the GSK Speak Up Integrity Lines through which alleged breaches of legal or regulatory obligations, financial fraud (including accounting internal controls and auditing), or any other alleged contravention of GSK's Code of Conduct (PDF) and company policies can be reported using different communication channels. Concerns may be reported anonymously if desired.

A secure, offsite post office box may also be used:

Mailing Address:
Box 58572
Philadelphia
Pennsylvania 19102
USA

Please do not use the Speak Up Integrity Lines or post office box above for product enquiries or to report adverse events. Visit the contact us page for instructions on where to submit questions on these matters.

GSK's Code of Conduct

GSK's Code of Conduct (PDF) is the foundation for all the company policies. It sets out the fundamental principles that the company values and that employees should apply in their daily work. Supporting the Code of Conduct policy is a range of corporate policies providing specific guidance in areas such as competition law, marketing practices, non-discrimination, share dealing, and conflicts of interest. GSK's employee guide to business conduct highlights the Code of Conduct, core compliance policies and provides guidance to employees. It is the responsibility of each employee to implement the code and follow the employee guide to sustain the trust and confidence of all GSK stakeholders.

GSK Code of Conduct translations (PDFs)

Arabic                                     Indonesian                             Romanian

Brazilian-Portuguese               Italian                                     Russian

Chinese                                   Japanese                               Spanish-EU

Czech                                      Korea                                     Thai

French                                     Malay                                     Traditional Chinese

German                                   Urdu                                       Turkish

Hindi                                        Polish                                     Vietnamese

Hungarian                                Portugese-EU

GSK’s Public Policy Statement on Working with Third Parties

At GlaxoSmithKline (GSK), we are committed to operating to the highest ethical standards to help maximise the long term sustainability of our business and of the communities in which we operate.  We aim to comply with all laws, rules and regulations governing our activities and, in addition, have developed a comprehensive framework of GSK policies, guidelines and standard operating procedures to help drive high ethical standards. 

We strive to conduct business with third parties including suppliers, distributors, equity stake holdings and other business partners (collectively, “Third Parties”) who share our commitment to high ethical standards and operate in a responsible way.

As such, GSK’s Public Policy Statement on Working with Third Parties sets out our expectation that Third Parties will:

  • Share our commitment to high ethical standards
  • Comply with all applicable laws and regulations and adopt, at a minimum, GSK’s Anti-Bribery & Corruption and Labour Rights Principles
  • Where relevant, comply with our standards on quality, patient safety, health and safety and the environment
  • Create a culture which supports staff reporting of suspected violations of law, rules and regulations, as well as of unethical conduct, without fear of reprisal or retaliation.

Third Parties should also reference our general terms and conditions on this website’s Procurement page.

Complying with the UK Corporate Governance Code

Throughout 2015, GSK complied with the provisions of the 2014 edition of the UK Corporate Governance Code that is maintained by the Financial Reporting Council (FRC), with the exception of Code provision C.3.7. which requires audit contract tenders to be undertaken at least every 10 years. Page 92 of GSK's 2015 Annual Report sets out details of the audit contract tender process being undertaken during 2016. 

Annual Report 2015

UK Corporate Governance Code – find out more on the Financial Reporting Council website

New York Stock Exchange rules

The New York Stock Exchange rules permit GSK to follow UK corporate governance practices instead of those that apply to the US, provided we disclose any significant ways in which our practices differ from those applying to US domestic issuers.

A table disclosing differences between GSK's domestic corporate governance practices and those applying to US domestic issuers is included in our Annual Report on Form 20-F.

California compliance law

Section 119402 of the California Health and Safety Code requires a pharmaceutical company to adopt a Comprehensive Compliance Program that is in accordance with the US Department of Health and Human Services, Office of Inspector General's "Compliance Program Guidance for Pharmaceutical Manufacturers". We must also comply with the Pharmaceutical Research and Manufacturers of America Code.

Further, the law requires that the Comprehensive Compliance Program includes an annual limit for certain items and activities given to healthcare professionals covered by this California law.
Finally, the law requires that each manufacturer make its Comprehensive Compliance Program and an annual declaration of compliance publicly available.

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