Corporate Responsibility Report 2008

Assurance

SGS Assurance statement

SGS UNITED KINGDOM LTD’S REPORT ON ENVIRONMENT, HEALTH AND SAFETY DATA IN THE GLAXOSMITHKLINE CORPORATE RESPONSIBILITY REPORT FOR 2008

NATURE AND SCOPE OF THE ASSURANCE
SGS United Kingdom Ltd was commissioned by GlaxoSmithKline (GSK) to conduct an independent assurance of the Environmental, Health and Safety data in their Corporate Responsibility (CR) Report for 2008. The scope of the assurance, based on the SGS Sustainability Report Assurance methodology, included 2008 data contained in the following sections of this report:

Waste water	Injury & illness rates
Waste	Injury & illness causes
Emissions to air	Fatalities and serious injuries
Climate change	Ergonomics
Energy	Driver safety
Transport impact	Health and safety data table
Water use
Environment data table

The information in the GSK CR Report and its presentation are the responsibility of the directors and management of GSK. SGS United Kingdom Ltd has not been involved in the preparation of any of the material included in the CR Report. Our responsibility is to express an opinion on the data, graphs and statements within the scope of verification. Financial data drawn directly from independently audited financial accounts has not been checked back to source as part of this assurance process.

The SGS Group has developed a set of protocols for the Assurance of Sustainability Reports based on best practice guidance provided in the Global Reporting Initiative Sustainability Reporting Guidelines (2006) and the AA1000 Assurance Standard (2003). These protocols follow differing levels of Assurance depending the reporting history and capabilities of the Reporting Organisation.

This report has been assured for content veracity. The assurance comprised a combination of interviews with relevant employees; documentation and record review at nineteen GSK locations during and at the end of the reporting year as follows:

Interim site visits during October 2008 in France (Evreux, Notre Dame de Bondeville, Saint-Amand-Les-Eaux), India (Nabha), Italy (Verona - GMS and R&D), Nigeria (Agbara), UK (Slough, Stevenage R&D, Ware GMS, Worthing) and USA (Clifton, Memphis, Research Triangle Park R&D).
End of year site visits during January and February 2009 in India (Nashik, Thane), Ireland (Cork) and UK (Irvine, Ulverston and Corporate CSR function in London).

The sites selected included those submitting high proportions of key data and included all parts of the GSK business.

STATEMENT OF INDEPENDENCE AND COMPETENCE
The SGS Group of companies is the world leader in inspection, testing and verification, operating in more than 140 countries and providing services including management systems and service certification; quality, environmental, social and ethical auditing and training; environmental, social and sustainability report assurance.

SGS United Kingdom Ltd affirm our independence from GSK, being free from bias and conflicts of interest with the organisation, its subsidiaries and stakeholders. The assurance team was assembled based on their knowledge, experience and qualifications for this assignment, and comprised auditors and assurors registered with IRCA, IEMA and EMAS Verifiers.

ASSURANCE OPINION
On the basis of the methodology described and the verification work performed, we are satisfied that the Environmental, Health and Safety data contained within the GSK Corporate Responsibility Report 2008 is reliable and provides a fair and balanced representation of GSK’s Environmental, Health and Safety activities in 2008. We believe that GSK has chosen an appropriate level of assurance for this stage in their reporting.

Key areas for improvement to data collection, submission and manipulation were identified during the assurance process and, as far as possible, were addressed to incorporate improvements into this report. These improvement opportunities are outlined below to enable further review to establish the need for system or process changes in future reporting cycles:

Some data points which are collated centrally at year end were not fully reviewed to identify anomalies leading to an inconsistent approach in estimating missing data.
Several data points have been calculated using new emissions factors and previous years’ data is restated using the same calculation to allow year-on-year comparison. It is important to ensure that any restated information is fully explained and references to factors used remain current.
Some significant contributors to selected data points failed to submit required information.
Calculation methodology for ozone depleting substances from patient use of inhalers was updated for one production site but not the remaining sites.
It was noted that reported data for previous years may change slightly due to obtaining additional data submissions or updating estimates after publication date.
Some anomalies were identified in data submitted when reviewing site level data and comparing 2008 with previous years’ submissions. Some of these included examples where data had been entered twice following a change to the database.
Improvement opportunities identified from site visits were mainly site specific with the most common observations focussing around the following areas:

Manual transfer of data and the opportunity for mistakes and variations in roundings in transfer;
Utilising the benefits of improvement in regular review and internal checks of data accuracy and formalising secondary review of manual transfers, rather than end of year checks;
Extension of monthly reporting rather than quarterly or annual.

Improvements identified in previous reporting period have started to be implemented as follows:

Specific reports in EHS manager have begun to be implemented, such as the energy module, to reduce the need for additional data transfer from spreadsheets at site level. There may be additional opportunities to extend this to other areas such as waste data provided by key subcontractor.
During site visits conducted it was noted that the staff were well prepared and able to provide required evidence to the auditors in the majority of cases, particularly on sites which had undergone previous visits. In addition required changes were generally made promptly where possible.
Data from ancillary services or site activities has started to be included, with explanation provided in the comments section of EHS Manager, however site visits identified that there remain some missing items.
Review of data submissions indicated an increase in monthly reporting rather then annual or quarterly allowing for more regular review and update of data entries and also indicating discrepancies more clearly.
The majority of site visits were conducted in the last quarter of 2008 which enabled issues of concern to be identified and dealt with earlier in the assurance process.

Key areas for improvement in data verification process were identified as follows:

Sites selected for visits should be identified at the earliest opportunity in order to enable visits to be completed alongside ISO14001/OHSAS18001 certification audits where possible.
Recommended that site visits are completed during the last quarter of 2009 to enable any follow-up required to be completed before end of year verification is performed.
Recommend selection of key indicators for full review of calculation methodologies across all major contributors, for example VOC and COD emissions and hazardous waste disposal for Primary sites.
Recommend site visits include detailed review of source evidence for ozone depleting substances from equipment.
Recommend sites selected for visits include:

a sample of sites manufacturing inhalers in order to verify data back to source;
a sample of sites with significant contributions that failed to submit data; and
a sample of sites where significant changes have occurred which were reflected in data submitted.

Signed:
For and on behalf of SGS United Kingdom Ltd

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