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• Training and awareness

Training and awareness

We have training and awareness programmes to make sure employees understand our policies, comply with the law and know what standards of behaviour are required.

Training starts with an induction course for new employees in the UK and the US. This covers the GSK Code of Conduct and other relevant policies. Induction training for new sales and marketing employees covers our marketing codes of practice. These induction courses ensure that new employees understand the importance of ethical conduct from day one, know how to deal with dilemmas and where to seek help.

We provide additional training for employees who will be working in areas where there are additional regulatory requirements such as R&D, manufacturing and sales and marketing.

Sales representatives receive detailed training on the medicines they promote and the diseases they are designed to treat. Sales employees are given training on appropriate marketing practices and are required to pass a test on our marketing code before starting their sales role.

Regular refresher courses are held for all sales and marketing employees at least annually. For example, in some markets, employees look at examples of ethical dilemmas and issues that they could face in their work and guidance is provided to help them understand appropriate responses. Employees are encouraged to ask themselves the following questions before making a decision:

• Would I be embarrassed if my friends or family knew what decision I have made?
• How would my decision look to a cynic?
• What could the newspaper headline look like?
• Am I still confident that this is the right decision for GSK?

We monitor the success of our training and awareness programmes. For example in the US we conduct surveys of GSK sales representatives. In 2005, the survey revealed that:

• More than 98% of employees rated efforts to promote compliance as effective.
• More than 90% of representatives correctly answered questions on the promotional materials and sample management policies.
• Over 175 employees suggested solutions to handle compliance challenges.

We also conduct a global management survey every two years. The 2004 survey showed that 92% of managers said they understood how the GSK Code of Conduct applied to their jobs.

Activity during 2005
We launched a new half day workshop on “Ethical Decision Making”, which was attended by almost 500 senior managers in the US and UK, including staff in corporate functions (such as Finance, HR, IT and Communications). This workshop gave participants practical tools to help with making ethical decisions, and highlighted managers’ obligations under the Employee Guide to Business Conduct and the risks associated with non-compliance.

The managers who attended the “Ethical Decision Making” workshops chose to attend. It was recognised that there is a need to involve and engage more managers throughout GSK on an ongoing basis. So, in 2006 we will launch an additional ethics eLearning and face-to-face training package for managers.

Over 1,000 new sales and marketing staff in the US received training on compliance policies and more than 10,000 existing staff received two hours of annual refresher training in 2005. We do not track sales and marketing training hours in other countries. Anther initiative to improve employee understanding is a yearly bulletin launched by the US Pharma Compliance Office on the major types of unethical conduct detected and the actions taken.

Over 1,200 R&D employees completed the ‘Performing with Integrity’ course during 2005. This course was established in 2004, when more than 9,000 R&D employees completed the course. This includes training on the Code of Conduct, and our policies on Conflicts of Interest and Acceptance of Gifts and Entertainment by GSK employees.

Objectives for 2006

• Review the ‘Performance with Integrity’ face-to-face induction training session and make appropriate changes for new staff in the UK and the US during 2006.
• Launch an additional ethics eLearning and face-to-face training package, building on the ‘Ethical Decision Making’ workshop for managers.

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