• Home
• Responsibility
• CR Report 2005
• Ethical conduct
• Marketing ethics
• Marketing codes of practice

Marketing codes of practice

Our Pharmaceutical Marketing and Promotional Activity policy applies to all employees and agents. It commits us to promotional practices that are ethical, responsible, principled and patient-centred. It prohibits kickbacks, bribery or other inducements to doctors.

This policy is supported by regional marketing practices codes in Europe, our International region, Japan and the US. These codes apply the same ethical standards but reflect differences in market structures, national healthcare systems and regulations. They incorporate the principles of industry codes of practice such as the EFPIA, IFPMA, JPMA, and PhRMA marketing codes.

The codes explain our policies on issues such as:

• Providing full and accurate information – information can only be provided on approved uses for a medicine. Information must be accurate, balanced, fair, objective, unambiguous and up-to-date.
• Gifts to healthcare professionals – gifts must be given only occasionally and must be relevant to the practice of medicine. Gifts cannot be made as an inducement to prescribe any of our medicines.
• Appropriate hospitality for meetings – no entertainment is permitted. Hospitality (such as travel costs or food) may only be provided for meetings with an educational purpose. The level of hospitality must be appropriate to the occasion and must only be provided for relevant healthcare professionals, not spouses, children, office personnel, or any other guests. Travel costs are not provided in the US.

Our regional codes are available in more than 30 local languages and employees can access them via the intranet. All sales and marketing staff receive training on the codes; see Training and awareness.

Progress in 2005
In 2005, GSK’s president of pharmaceutical operations and his direct reports conducted a review of our regional marketing codes to confirm that GSK’s codes are comprehensive and consistently applied in all regions. We identified certain areas for improvement, and will update the codes in 2006 accordingly. Changes will include reducing the maximum value of nominal gifts to healthcare professionals to $10 (less than £6), and prohibiting gifts and entertainment for medical professionals retained as consultants to GSK. We will also ensure that decisions about grants for medical education, and about donations for charitable purposes, are reviewed by departments independent of sales and marketing.

We launched a new procedure in Europe on sponsored attendance of doctors at medical conferences. This procedure specifies the circumstances under which sponsorship is appropriate and governs the provision of appropriate travel, meals and accommodation.

Compliance with policies and procedures is a formal performance objective for sales and marketing employees in the US. This is evaluated as part of employee performance reviews, thus encouraging employees to view compliance as an integral part of their overall performance. US employees in our pharmaceutical business were appraised against 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 are evaluated against the following objective:

"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."

Back to top