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Monitoring

We monitor awareness of ethical issues and company policies through our Integrity Helplines, reporting channels and regular surveys.

As part of our commitment to continuous improvement, we benchmark our compliance programme against other major companies, our industry peers and government and regulatory standards.

Monitoring awareness of ethical issues
Our Leadership Survey in 2004 included questions on business ethics. The survey was completed by over 9,500 managers and the results were encouraging:.

• 91% of respondents felt that people in their department show commitment to performance with integrity.
• 92% said they understood how the GSK Code of conduct applied to their jobs.
• 76% felt that they could report unethical practices without fear of reprisal.

These results help us to identify the areas we need to focus on. Where necessary we direct ethics training to the business units that scored lower than average on these questions.

GSK corporate ethics and compliance function
GSK has a dedicated compliance function that works with the GSK business units to identify compliance issues and how to address them. In 2004 we increased the number of full-time compliance officers from four to eight. Compliance officers are all senior level managers, with direct access to the leadership teams of GSK functions. They are a source of expertise and a point of contact for anyone with a question on ethics or compliance with GSK policies.

Compliance officers are also responsible for defining the training needs of their section of the organisation and communicating the latest news, policies and legislation affecting GSK.

Reporting concerns
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.

The Helplines and post office box are promoted through the Employee Guide to Business Conduct, on the GSK intranet and during training. The Corporate Ethics and Compliance function is promoted as a source of information and advice, as well as a mechanism for reporting concerns. Data from 2004 suggest employees understand this and see it as a useful source of advice and guidance. During 2004 there were 2,580 contacts with the compliance functions of which 75% were from employees seeking advice or information. The remaining 25% were from employees reporting suspected cases of misconduct.

Addressing misconduct
Our Corporate Ethics and Compliance department ensures that all allegations and suspected cases of misconduct are investigated. We are committed to taking firm steps to stop misconduct. Disciplinary action, up to and including dismissal, is taken where necessary.

Data on disciplinary actions have traditionally been collected and held by local human resources departments where it is of most operational value to the company. In 2004 we began to collate this information for the first time and have collected data from all our major business units (including Pharmaceuticals, Manufacturing, Corporate, Consumer healthcare and R&D). We believe the data to be a reasonable reflection of 2004. During this process we identified ways to improve the categorisation of disciplinary actions and the mechanics of the data collation. This will improve the quality of data in future reports.

In 2004 there were 954 disciplinary actions taken as a result of investigations into allegations of misconduct. This included 256 dismissals and separations. Other disciplinary actions included verbal and written warnings, and in some cases, financial penalties. Employees staying with the company received re-training and increased monitoring.

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