Sarbanes-Oxley Act 2002
Find out how GSK conforms with the 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 standards for corporate accountability in the USA. Although our corporate governance structure was believed to be robust and in line with best practice, certain changes were necessary to ensure compliance with Sarbanes-Oxley.
The Sarbanes-Oxley code of ethics
Sarbanes-Oxley requires GSK to have a code of ethics "applicable to its Principal financial officer and controller or Principal accounting officer, or persons performing similar functions".
The code is defined as having standards that promote:
- honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships
- full, fair, accurate, timely, and understandable disclosure in the periodic reports required to be filed by the issuer
- compliance with applicable governmental rules and regulations
GSK formulated a Sarbanes-Oxley code of ethics around seven 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 employees. The Chief Executive Officer and Chief Financial Officer have both signed statements certifying their compliance with the code of ethics, as have the Senior Vice President, Financial Controller and the Senior Vice President, Finance Services.
- Code of Conduct
- Protection of GSK Information (PDF)
- External Communications to Investors and Media; External Speaking Engagements and Publications (PDF)
- Political Contributions (PDF)
- Preventing Corrupt Practices and Maintaining Standards of Documentation (PDF)
- Risk Management and Legal Compliance (PDF)
- Code for Dealing in Securities (PDF)
More on governance
At GSK we are committed to operating at the highest standards of corporate governance
Discover the details of our various Board committees, who sits on them and what the committees do
Discover the details of our other specific committees, such as the Disclosure Committee, who sits on them and what they do
Board of Directors
The Board of Directors is responsible for the group's system of corporate governance and is ultimately accountable for the group's activities, strategy, risk management and financial performance.