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Ethical conduct

What is GSK's commitment to ethical sales and marketing?

Putting the patient first is at the heart of ethical conduct for a pharmaceutical company. This means maintaining high ethical standards during all stages of R&D and once a product is approved for marketing.

What we are doing

Marketing ethics is a particularly important aspect of ethical conduct for GSK and one that is relevant to patient safety. It is essential that our marketing practices help doctors to prescribe medicines that are in the patient’s best interests. We believe that sales representatives play an important role in providing up to date information on our products and their benefits to patients.

Our approach to marketing ethics
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 potential side effects, or that promotion for unapproved uses may be occurring despite increased training, monitoring and oversight.

Our approach to addressing these issues includes regional marketing codes of practice, detailed policies governing our relationship with healthcare professionals, regular training for employees and an extensive compliance system.

During 2007 we made improvements in a number of areas. One example is our new State Reporting System in the US. This system improves our reporting of expenditure with healthcare professionals, in line with legislation in several US states. It will allow us to identify and investigate situations where excessive meals and gifts may have been provided by GSK.

Questions from doctors on off-label uses for our products must be referred to our medical information department except in very specific instances relating to some oncology and HIV products. In the US, we improved our process for monitoring these referrals to help us ensure that representatives are not promoting off-label uses.

Training included our new Compliance University programme for US field sales managers and marketing staff. The programme provided a half day interactive course on key compliance areas. Senior managers and compliance officers took part to answer questions from attendees, help them explore potential ethical dilemmas and reinforce the importance of the subjects covered.

Reviewing our ethics programmes
Marketing ethics is one aspect of our broader ethics and compliance programme. In 2007, we completed a thorough review of this programme and identified a number of areas for improvement:

• Recruitment – we have included questions on ethics and integrity in the recruitment process and GSK Managers Interview Guide and will be carrying out more extensive pre-employment checks
• Management objectives – we will be establishing ethical leadership objectives for the top 1,800 GSK managers
• Training – when delivering employee training we plan to include an ethics component and to extend ethics and compliance induction training to new employees worldwide
• Integrity helpline – we will extend our independently managed helpline to all countries where we operate
• Senior management – we are developing new ethics awareness programmes for site directors and general managers who are key representatives of GSK in the countries and locations where they work

Q. If employees are still being dismissed for unethical conduct, are your policies working?  

A. In 2007, 320 employees were dismissed or agreed to leave the company voluntarily as a result of policy violations. Unethical conduct occurs in all companies. We believe these figures demonstrate the effectiveness of our monitoring and compliance programmes. Furthering our ethical culture, recruiting the right people, providing the right training and tools, improving our checks, and encouraging people to speak-up, enable us to identify and address unethical conduct in a consistent and responsive manner.

Q. Is GSK unduly influencing doctors?  

A. We take several approaches to protect against inappropriate influence of doctors including regional marketing codes of practice, regular training and monitoring. Our policies apply to all employees and agents and commit us to promotional practices that are ethical, responsible, principled and patient-centred. They prohibit kickbacks, bribery or other inducements to doctors, and any promotion for unapproved uses of our medicines. Our sales force is regularly trained and supervised by managers who monitor educational events, visits to doctors and expenses.

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