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Corporate Responsibility Report 2008

Code of Conduct and business ethics

Code of Conduct

The GSK Code of Conduct sets out the standards we expect from our employees and contractors. It contains the following key requirements:

  • Conduct business with honesty and integrity and in a professional manner that protects GSK’s good public image and reputation
  • Build relationships with customers, vendors, suppliers and fellow employees based on trust and treat each of these individuals with respect and dignity when conducting business
  • Become familiar with and comply with legal requirements and GSK policy and procedures
  • Avoid any activities that could involve or lead to involvement in any unlawful practice or harm to GSK’s reputation or image
  • Avoid actual or potential conflicts of interest with GSK, or the appearance thereof, in all transactions

Read the full Code of Conduct.

Our Employee Guide to Business Conduct builds on the Code and explains what employees must do to meet its requirements.

Business ethics

Corrupt and anti-competitive behaviour undermines fair competition, inhibits economic development and is bad for economies, business and people.

Our Employee Guide to Business Conduct contains the policies and guidance to ensure that we operate within the letter and spirit of the law and maintain high standards of ethical business behaviour.

Anti-competitive behaviour

We are committed to free and open competition. We succeed as a company because of the high quality and competitiveness of our products and the talent and commitment of our employees.

Our policy on anti-competitive behaviour covers issues such as mergers, abuse of monopoly powers, resale price maintenance, predatory pricing and other restrictive agreements and practices. It sets out the standards of behaviour we expect from our employees and agents.

Preventing corruption

Our policy on anti-corruption forbids payments or inducements to political candidates, legislators, political parties and party officials, or government officials or employees, whether local or national, including officials and employees of government-owned enterprises and of public international organisations. We also have separate policies on political contributions or donations and on acceptance of gifts or entertainment by our employees.

Sample questions from our Employee Guide to Business Conduct

Question: We have received an order for an unusual volume and combination of pharmaceuticals from a new customer in a location noted for political instability. The shipment location is in another country, and the customer has said we should not bother including the usual consumer use information. Is this a problem?

Answer: There are enough red flags here that you need to get advice from the GSK Legal Department. The information you have indicates that this material might be shipped to a prohibited country or used for improper or even terrorist activity. You need to know your customer and get advice on what to do.

Question: A vendor offers to sell a GSK product manager a mailing list of 10,000 names of individuals who are being treated for depression. Are there any concerns with the purchase of such a list?

Answer: Yes. Many countries, including the US and those in the EU, have established strict laws protecting healthcare information that identifies an individual. Written authorisation by each individual is usually required for GSK to receive this information.