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Marketing training and compliance

We recognise that strong policies and codes of practice do not guarantee that all employees will meet our standards. Commercial pressures and complex regulatory environments can sometimes present our employees with difficult ethical dilemmas.

This is why we provide regular training for sales and marketing employees that reinforces the importance of ethical conduct and helps them to understand the behaviour expected of them.

Internal compliance systems are designed to identify and address breaches of our codes.

Training and awareness
Sales representatives receive detailed training on the medicines they promote and the diseases which they are designed to treat.

Sales and marketing employees are also given training on appropriate marketing practices and their obligations and responsibilities under our marketing codes. Practice varies by region but employees receive training when they are hired, with refresher courses on an on-going basis.

Progress during 2004
During 2004 area champions coordinated training on our new regional codes. Information on the codes is being added to induction training for all new employees, regardless of whether they will have a sales or marketing role.

In 2004 sales and marketing staff were either trained or recertified their understanding of the sales and marketing code. This was a global effort in which:

• over 1,100 new staff in the US were trained and nearly 8,000 existing staff completed recertification on policies;
• over 10,000 sales and marketing staff in Europe were trained on the regional sales and marketing code;
• in our International region training was delivered in all seven regional business units.

Training is provided in a variety of ways, including self-study, on the job training by managers, web-based learning and in-house courses. Sales staff are required to pass a test on our code of practice before starting their sales role.

In the US, sales and marketing employees are now required to assess their compliance with our marketing codes as part of their annual performance and development plan appraisal. This encourages employees to view compliance as an integral part of their overall performance.

Monitoring and compliance
Sales representatives are supervised by sales managers who regularly monitor educational events, visits to doctors, and expenses, to ensure best practices are observed. This is supplemented by additional monitoring by independent staff as needed in certain areas.

Sales managers are directed to report issues and infractions to regional compliance officers or senior managers. They are encouraged to do this through normal line management channels, but have the prerogative of making reports directly to Corporate Ethics and Compliance if necessary. All issues are investigated and appropriate action determined, with referral to the Corporate Ethics and Compliance department as appropriate.

Employees are also encouraged to report concerns or suspected breaches of our marketing codes through their line manager, compliance officer, or confidentially through our Integrity Helplines and offsite PO Box (in the US).

Staff in local market customer response centres are trained to deal with concerns about marketing practices that might be raised by healthcare professionals, patients or the public. They redirect calls to appropriate senior management or a compliance officer if necessary.

Our internal audit department also audits sales and marketing practices during regular audits of the business.

During 2004, specifically as a result of breaches of sales and marketing codes, 87 employees were dismissed or agreed to leave the company voluntarily. In addition there were 109 cases of employees being issued with written warnings, which included remedial training, and in some cases, financial penalties.

These figures form part of the overall figures reported in Standards of Ethical Conduct.

Objectives for 2005
Sales and marketing compliance advisers will be appointed in the US during 2005. They will work with the business units to ensure that compliance and ethics policies are fully integrated and embedded.

A Compliance Analysis and Reporting group will also be set up in the US to review compliance monitoring, auditing and investigations data and advise GSK management on compliance related issues.

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