CORPORATE ETHICS AND COMPLIANCE
GSK is committed to operating within the law and to the highest ethical standards. The healthcare industry is highly regulated and the discovery, development, manufacturing and marketing of medicines are complex processes. Thus, we aim to build adherence to high standards into the everyday management processes of these activities.

Formal company polices and procedures set out the expected standards of conduct, but effective communication and training on these standards, followed by regular monitoring and periodic review of work output, are critical. While lawyers and compliance officers are closely involved in establishing and communicating standards, GSK emphasises the personal responsibility of employees and their line managers for ensuring that all employees observe these principles in their everyday work. To support this we undertake ethics training through computer-based sessions and interactive discussions.

The Corporate Ethics and Compliance function at GSK is responsible for supporting the development and implementation of practices that facilitate employees’ compliance with laws and company policy. Specialist compliance officers support our main operations of Pharmaceuticals, Consumer Healthcare, R&D and Manufacturing.

An internal control framework integrates ethics and compliance with the day-to-day management of the Group. This framework supports line management in the identification and mitigation of significant risks, among which are potential compliance failures.

The framework includes a Risk Oversight and Compliance Council, as well as sector and other business unit risk management and compliance boards. The Risk Oversight and Compliance Council and boards assist in the identification and mitigation of risks and provide guidance on risk management initiatives at the corporate and business unit levels.

The Risk Oversight and Compliance Council reports to the Audit Committee of the GSK Board and the Chief Executive Officer, and will also report to the Corporate Executive Team. The reporting line to the Audit Committee provides a mechanism for bypassing the executive management if irregularities are ever identified.

GSK POLICIES
The GSK Code of Conduct and all GSK policies are available on our internal website. In 2002, a guide to business conduct was published on the internal website to support employees’ understanding and implementation of these standards. The guide summarises policies and explains the company’s expectations on business ethics and good business conduct.

NOTIFICATION SYSTEMS
Confidential Integrity Help Lines to compliance officers are available for employees to report concerns they feel are not being dealt with adequately through the normal management system.

These Help Lines are available to employees in the UK and US, reaching about half the total GSK workforce. Other employees can take advantage of e-mail access to a compliance officer, or can report concerns through a confidential post office box maintained by Corporate Ethics and Compliance.

The Help Lines are primarily used for consultations and by employees to ask questions. As a result, the number of callers and inquiries received by compliance officers tends to increase in response to training or to changes in or issuance of new policies. Activity levels reflect greater awareness of policies and legal requirements rather than trends in unacceptable practices. Response levels indicate that the existence of the systems and their purpose are well understood.