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Ethical conduct

Patients, consumers, doctors and governments want to use medicines from companies that they trust. Our ethics policies require all GSK employees to meet the highest standards of ethical and legal compliance in their work.

Embedding ethical behaviour needs a combination of clear systems (policies, training and monitoring) and an unambiguous corporate culture, in which it is understood that everyone is required to behave with honesty and integrity.

Here we explore a few aspects of ethics at GSK - including our standards for marketing practices. Much more detail is provided in our full report.

Marketing ethics
Our specialist sales representatives meet regularly with doctors and pharmacists to inform them about our medicines and their approved uses.

We believe that sales representatives play an important role in providing up-to-date information to doctors on our products and their benefits to patients. However, we know that some people are concerned that marketing by pharmaceutical companies exerts undue influence on doctors, that sales representatives do not always give doctors full information about a product's risk, or that promotion for unapproved uses may occur despite increased training and monitoring and oversight by governments.

In the past few years we have revised and strengthened our commercial policies in a number of areas and have extended our training for sales and marketing teams. Some sales practices that were commonplace five or ten years ago in our industry are now prohibited. Hospitality may only be provided for healthcare professionals when the meeting has an educational purpose, and cannot be provided to spouses, children, office personnel, or any other guests. Another example is that in the US sales representatives cannot give practice-related gifts to healthcare professionals where the value exceeds $10 (less than £6).

We have also strengthened our compliance systems and appointed a network of compliance officers. We are now supporting efforts to strengthen marketing standards across the pharmaceutical industry. In 2006 GSK played a key role in revising and strengthening the Codes of Marketing Practices for the International Federation of Pharmaceutical Manufacturers Association (IFPMA) and the European Federation of Pharmaceutical Industries Associations. We are a member of IFPMA’s newly formed Code Compliance Network that will support implementation of the standards through training and education. We are also supporting many efforts at country level, for example:

• Greece – we are leading the industry body working group set up to improve the local code of practice.
• Korea – we led efforts to improve the Korean Research-based Pharmaceutical Industry Association’s Code of Conduct and to have this endorsed by the Korea Fair Trade Commission.
• Sri Lanka – we led efforts to create the first marketing code for the Sri Lanka Chamber of the Pharmaceutical Industry based on the IFPMA Code.

Reporting channels
Employees are encouraged to seek help and to report any concerns or suspected cases of misconduct. They can do this through their line management, our network of compliance officers, or through our confidential Integrity Helplines or, in the US, our offsite post office box.

Reporting channels are promoted through our Employee Guide to Business Conduct, on the GSK intranet and during training.

In 2006 there were:

• 5,363 contacts with the compliance functions. This is an increase from 3,644 in 2005, and 2,593 in 2004.
• Of these, 81 per cent were from employees seeking advice or information; 19 per cent were from employees reporting suspected cases of misconduct.

We believe that the increase in contacts with our compliance functions is due to our efforts to promote high standards of ethical behaviour and to raise awareness of our Integrity Helpline as a compliance resource.

Managers certification

Every year all GSK managers are required to certify their compliance with the following statement:

I have read, understood and shall comply fully with the policies and procedures specified in the Learning Activity:

• I understand that GSK is committed to the principle of performance with integrity, and in particular, to ensuring that its activities comply with all applicable laws.
• I have received a copy of or have access to the GSK Code of Conduct (POL-GSK-001) and other GSK corporate policies through the Corporate Policy Index page accessible on the Corporate Ethics & Compliance Community.
• I have read and understand The Employee Guide to Business Conduct, accessible on the Corporate Ethics & Compliance Community.
• I have complied with applicable laws, regulations, and GSK corporate and local policies and procedures.
• All people under my supervision have received copies of or have access to the GSK Code of Conduct and other applicable GSK policies and have been informed of their responsibilities.
• I have put in place appropriate measures to ensure that the people under my supervision comply with applicable laws, regulations, and GSK corporate and local policies and procedures while working on behalf of GSK.
• I understand my responsibility to promptly report any actual or suspected violations of the law, regulations, or GSK corporate and local policies and procedures.
• I have reported all actual or potential compliance issues of which I am aware concerning legal requirements or company policies.

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