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Marketing codes of practice

Our sales representatives promote our products. They do this by providing information to doctors so they understand our products and the benefits they can deliver to patients.

Our marketing policies and codes of practice give guidance to sales and marketing employees about the high ethical standards we require. Our codes stress that all marketing and promotion must be based on valid scientific evidence, be consistent with national prescribing documentation, and comply with the law. Inducements such as gifts or bribes are never acceptable under any circumstances.

All GSK employees must also abide by our Code of conduct and Employee Guide to Business Conduct. The Employee Guide contains a specific section covering our customers and marketplace. See Code of Conduct and Employee guide to business conduct.

Marketing policies and codes of practice
Our company-wide policy on pharmaceutical marketing and promotional activity applies to all employees and agents. It commits us to promotional practices that are ethical, responsible, principled and patient-centred. It prohibits bribery or other inducements to doctors.

In December 2003 we introduced regional marketing practices codes in Europe, International and Japan (marketing codes were already in place in the US). These codes apply the same ethical standards in all regions but reflect differences in market structures, national healthcare systems and laws and regulations.

We also adhere to international and regional industry codes of practice. These include the IFPMA, PhRMA, EFPIA and JPMA marketing codes.

Progress during 2004
During 2004 GSK’s regional codes were translated into major local languages and rolled out across GSK. Sales and marketing employees now have access to them on the intranet and many have received printed copies. Area champions in each country have coordinated distribution and training on the new codes. The European code of practice includes a quarterly reporting mechanism where the markets confirm whether any breaches of the code of practice have occurred, the severity of any breaches and what actions have been taken to prevent recurrence.

We also developed and distributed a new ‘Guide to US Healthcare Law’ for our US Pharma employees. While this information was previously provided through training, the new guide provides a concise and easy-to-read overview of the complex legal requirements applicable to health care businesses in the US. The guide supports our commitment to an ethical culture in which employees have a good understanding of GSK’s sales and marketing policies and the legal framework behind them.

Compliance with policies and procedures is a formal performance objective of sales and marketing employees in the US. This is evaluated as part of employee performance reviews. All US Pharma employees must include the following objective in 2005:

"Consistently follow company policies and procedures, take and complete required compliance training in a timely manner, and report compliance issues to manager, Legal or Compliance."

In addition, managers must include the following:

"Ensure that supervised employees are trained on company policies and procedures and have taken all required training, and provide oversight and direction to supervised employees so that they are in compliance with company policies and procedures."

Objectives for 2005
We plan to analyse the differences amongst the GSK International, European and US codes of practice and local requirements in an effort to consolidate and harmonise these codes as appropriate.

The US will continue to enhance its compliance programme with the addition of resources to act as sales and marketing compliance advisers. These advisers will work with the business units to ensure that compliance and ethics policies are fully integrated and embedded.

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