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Code of conduct

We recognise that commercial pressures and complex regulatory environments can present our employees with difficult ethical dilemmas. There are a number of ways in which we support employees to make the right choice, comply with Group policies, regulations and the law and attain the highest ethical standards in their work:

• Our Employee Guide to Business Conduct promotes honest and ethical conduct by setting out the standards to be followed by GSK’s employees in their everyday work for the company. It contains the Group policies that require all employees to act with integrity, comply with the law, avoid conflicts of interest and report any violations or unethical behaviour.
  
  Detailed guidance is provided, including real-life examples, on what constitutes acceptable or unacceptable behaviour. All GSK employees have access to the guide via the company intranet.
• Our induction training familiarises new employees with business conduct standards and where they can obtain support and guidance.
• We have a dedicated Corporate ethics and compliance function comprising full-time compliance officers who work with business units to identify compliance issues and how to address them. These Compliance officers are all senior level managers, with direct access to the business unit leadership teams. They are a source of expertise and a point of contact for anyone with a question on ethics or compliance with Group policies.
  
  The Compliance officers define the ethics and compliance training needs of their respective business unit and ensure that the latest news, policies and legislation affecting the business unit are effectively communicated.
• A Corporate ethics and compliance website is available on the company intranet.
  
  This contains links to all the Group policies, an ethical decision making model, an ethics quiz and links to many other resources including contact details of Compliance officers with whom they are encouraged to seek guidance or raise concerns with directly.
  
  The Compliance officer’s contact details are also published in a widely distributed booklet entitled “An Introduction to Corporate Ethics and Compliance”, over 50,000 of which have been distributed.
• A secure offsite PO box address is available for confidential written communication, and toll-free telephone “GlaxoSmithKline integrity helplines” are available in the US and UK.
  
  Employees are encouraged to seek help and to report any concerns or suspected cases of misconduct. They can do this through their line management, a compliance officer, or through our confidential Integrity Helplines or offsite post office box.
• We monitor awareness of ethical issues and Group policies through our Integrity Helplines, reporting channels and regular surveys. Our Leadership Survey, which is regularly conducted from a representative sample of several thousands, includes questions on business ethics.

GSK has global audit systems to help identify and deal with cases of non-compliance. Those who violate company standards are subject to disciplinary action including dismissal in serious cases. Serious violations and remedial actions are reported to the Audit Committee of the Board.

We recognise that doing the right thing can at times appear to sacrifice some immediate advantage but we believe that our commitment to integrity and high standards of business ethics benefit our customers, communities, shareholders, employees and the business.