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Code of conduct

Our Employee guide to business conduct sets out the standards of behaviour we expect from employees as well as the key compliance and ethics policies that guide our business activities. It requires all employees to act with integrity, comply with the law, avoid conflicts of interest and report any violations of the law or GSK’s policies or any unethical behaviour.

Guidance is provided, including real-life examples, on what constitutes acceptable or unacceptable behaviour. GSK employees have access to the guide via the company intranet. Our induction training familiarises new employees with business conduct standards and provides information on where they can obtain support and answers to questions.

Management certification on business ethics
Commitment to our Code of Conduct is reinforced by an annual management certification programme. This requires managers to certify that they comply with the statement below. In 2005 we expanded the programme to include over 12,000 managers worldwide. Eligible managers from all business units worldwide have completed the certification. Certification documentation is managed electronically and non-certification is tracked and followed up. Non-certification is typically due to extended leave of absence, such as maternity leave or long-term sick leave.

The full certification statement is reproduced below. The links have not been included below, as they are only accessible via the internal intranet. However, the Code of Conduct and The Employee Guide to Business Conduct documents are available from the ‘Responsibility’ section.

"I certify that:

I understand that GSK is committed to the principle of ‘Performance with Integrity’, and in particular, to ensuring that its activities comply with all applicable laws.

I have received a copy of or have access to the GSK Code of Conduct (POL-GSK-001) and other GSK corporate policies through the Corporate Policy Index.

I have read and understand The Employee Guide to Business Conduct.

I have complied with applicable laws, regulations, and GSK corporate and local policies and procedures.

All people under my supervision have received copies of or have access to the GSK Code of Conduct and other GSK policies and have been informed of their responsibilities.

I have put in place appropriate measures to ensure that the people under my supervision comply with the laws, regulations, and GSK corporate and local policies and procedures while working on behalf of GSK.

I understand my responsibility to promptly report any actual or suspected violations of the law, regulations, or GSK corporate and local policies and procedures.

I have reported all actual or potential compliance issues of which I am aware concerning legal requirements or company policies.

Exceptions (list any compliance issues that should have been reported previously but were not):"

In three markets, France, Germany and Belgium the statement and certification process are slightly different to reflect local legal requirements.

Business ethics and our suppliers
In 2005 GSK produced a booklet to help suppliers to understand the requirements that they must meet in order to work with GSK. The booklet outlines the importance that GSK places on operating to high ethical standards and includes reference to the GSK policy, to which GSK employees are bound, that prohibits the acceptance of gifts and entertainment. In working with GSK, suppliers are asked to understand and respect this position and as a supplier to GSK, they are asked to adopt and follow the same high standards within their business and in their interactions with GSK.


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